Authority For Advance Rulings Case Commentaries

BG Asia Pacific Holdings Pte Limited v. CIT: Clarifying Limitation of Benefits Conditions under India-Singapore DTAA

Date: Feb 26, 2021

BG Asia Pacific Holdings Pte Limited v. CIT: Clarifying Limitation of Benefits Conditions under India-Singapore DTAA Introduction The case of BG Asia Pacific Holdings Pte Limited v. CIT adjudicated...

Aircom International Ltd. v. CIT: Defining 'Fee for Technical Services' under India-UK DTAA

Date: Feb 5, 2021

Aircom International Ltd. v. CIT: Defining 'Fee for Technical Services' under India-UK DTAA 1. Introduction The case of Aircom International Ltd. v. CIT was adjudicated by the Authority for Advance...

AB Holdings Mauritius-II v. Authority For Advance Rulings: Establishing Criteria for Treaty Benefits and Anti-Avoidance Provisions

Date: Nov 9, 2017

AB Holdings Mauritius-II v. Authority For Advance Rulings: Establishing Criteria for Treaty Benefits and Anti-Avoidance Provisions Introduction The case of AB Holdings Mauritius-II (the Applicant) v....

Classification of Settlement Amount as Capital Receipt: A New Precedent in Indian Tax Law

Date: Jan 13, 2016

Classification of Settlement Amount as Capital Receipt: A New Precedent in Indian Tax Law Introduction The case of Lead Counsel Of Qualified Settlement Fund vs. Authority For Advance Rulings...

Taxation of Share Buybacks for Non-Resident Companies under Section 46A of the Income-Tax Act: An Analysis of Rst v. Director Of Income-Tax

Date: Feb 28, 2012

Taxation of Share Buybacks for Non-Resident Companies under Section 46A of the Income-Tax Act: An Analysis of Rst v. Director Of Income-Tax Introduction The case of Rst v. Director Of Income-Tax...

Strict Interpretation of Section 245R(2)(i) Proviso: Insights from Red Hat India Pvt Ltd Judgment

Date: Feb 4, 2012

Strict Interpretation of Section 245R(2)(i) Proviso: Insights from Red Hat India Pvt Ltd Judgment Introduction The judgment in Red Hat India Private Limited rendered by the Authority for Advance...

Barred Application Under Section 245R(2) in Offshore Supply Contracts: NPCIL v. Commissioner of Income-Tax

Date: Dec 22, 2011

Barred Application Under Section 245R(2) in Offshore Supply Contracts: NPCIL v. Commissioner of Income-Tax Introduction The case of Nuclear Power Corporation Of India Ltd. (NPCIL) v. Commissioner Of...

Taxation of Offshore Supply Contracts: LS Cable Limited v. Director Of Income-Tax

Date: Jul 27, 2011

Taxation of Offshore Supply Contracts: LS Cable Limited v. Director Of Income-Tax Introduction LS Cable Limited, a South Korean corporation engaged in manufacturing electric wires and cables, entered...

Determining Conditions for Completely Knocked Down (CKD) Imports: Insights from H-D Motor Company India Pvt. Ltd. v. Authority For Advance Rulings

Date: Jul 28, 2010

Determining Conditions for Completely Knocked Down (CKD) Imports: Insights from H-D Motor Company India Pvt. Ltd. v. Authority For Advance Rulings Introduction The case of H-D Motor Company India...

Refining the Scope of Fees for Technical Services and Permanent Establishment under India-UK DTAA: Insights from Real Resourcing Limited v. Dit

Date: Mar 6, 2010

Refining the Scope of Fees for Technical Services and Permanent Establishment under India-UK DTAA: Insights from Real Resourcing Limited v. Dit Introduction The case of Real Resourcing Limited v. Dit...

Non-Recognition of Liaison Offices as Permanent Establishments under DTAA: A Commentary on K.T. Corporation v. Director Of Income-Tax

Date: May 30, 2009

Non-Recognition of Liaison Offices as Permanent Establishments under DTAA: A Commentary on K.T. Corporation v. Director Of Income-Tax Introduction The case of K.T. Corporation v. Director Of...

Taxation of Long-Term Capital Gains for Non-Resident Companies: Insights from Four Star Oil & Gas Co. v. Director Of Income Tax

Date: Apr 1, 2009

Taxation of Long-Term Capital Gains for Non-Resident Companies: Insights from Four Star Oil & Gas Co. v. Director Of Income Tax Introduction The case of Four Star Oil & Gas Co. v. Director Of Income...

Classification of Shipbuilding Components: Central Excise Tariff Ruling in Cs India Steel Pvt. Ltd., In Re

Date: Feb 14, 2009

Classification of Shipbuilding Components: Central Excise Tariff Ruling in Cs India Steel Pvt. Ltd., In Re Introduction The case Cs India Steel Pvt. Ltd., In Re adjudicated by the Authority for...

Intertek Testing Services India P. Ltd. v. Authority for Advance Rulings: Clarifying Tax Obligations under DTAA

Date: Nov 6, 2008

Intertek Testing Services India P. Ltd. v. Authority for Advance Rulings: Clarifying Tax Obligations under DTAA Introduction The case of Intertek Testing Services India P. Ltd., In Re was adjudicated...

Classification of Transponder Leasing Payments: Insights from the ISRO Satellite Centre Ruling

Date: Oct 23, 2008

Classification of Transponder Leasing Payments: Insights from the ISRO Satellite Centre Ruling Introduction The case of ISRO Satellite Centre (ISAC) vs. Income Tax Authority adjudicated by the...

Clarifying Tax Exemptions for Government-Controlled Entities under Article 20 of the India-Korea DTAA

Date: Aug 30, 2008

Clarifying Tax Exemptions for Government-Controlled Entities under Article 20 of the India-Korea DTAA Introduction The case of Small Business Corporation Liaison Office In India v. Director Of...

Defining Royalty in Telecom Services: Dell International v. Commissioner of Income-Tax

Date: Jul 19, 2008

Defining Royalty in Telecom Services: Dell International v. Commissioner of Income-Tax Introduction The case of Dell International Services (India) Pvt. Ltd. v. Commissioner of Income-Tax,...

Taxation of NRO Deposits for Non-Resident Indians: V. Ravi Narayanan v. CIT

Date: Mar 4, 2008

Taxation of NRO Deposits for Non-Resident Indians: V. Ravi Narayanan v. CIT Introduction The case of V. Ravi Narayanan v. CIT was adjudicated by the Authority for Advance Rulings on March 3, 2008....

Inclusion of Foreign Tax Provisions in Book Profit under Section 115JA: Bank of India Ruling

Date: Nov 30, 2007

Inclusion of Foreign Tax Provisions in Book Profit under Section 115JA: Bank of India Ruling 1. Introduction The case of Bank of India, In Re adjudicated by the Authority for Advance Rulings on...

Taxation of Non-Resident Employment Income under Indo-Norway DTAA: Authority for Advance Rulings Decision in S. Mohan, In Re

Date: Aug 25, 2007

Taxation of Non-Resident Employment Income under Indo-Norway DTAA: Authority for Advance Rulings Decision in S. Mohan, In Re 1. Introduction The case of S. Mohan, In Re adjudicated by the Authority...