2012 (2) TMI 260 - AUTHORITY FOR ADVANCE RULINGS
Global Industries Asia Pacific Pte. Ltd., In re
DTAA with Singapore – Singapore company entered into contract with IOCL for residual offshore construction work and Installation of SPM - contract with L&T Ltd for installation and construction services for Single Point Mooring (SPM) - applicant cont ......
2012 (2) TMI 258 - AUTHORITY FOR ADVANCE RULINGS
Citrix Systems Asia Pacific Pty. Limited,
DTAA with Australia – Australian company entered into distribution agreement with Indian Company(IMI Ltd) for the distribution and sale of its software and hardware products in India - sale and collection of software product is made through the distr ......
2012 (2) TMI 173 - AUTHORITY FOR ADVANCE RULINGS
AREVA T&D India Ltd., In re
Indo-French DTAA – French Company entered into an IT Agreement with the applicant to provide support services in the area of IT - whether royalty or FTS – whether payment would fall under the provisions of Article 13 of the Indo France DTAA in view o ......
2012 (2) TMI 98 - AUTHORITY FOR ADVANCE RULINGS
Shell India Markets (P.) Ltd., In re
Double Taxation Avoidance Convention between India and UK – Cost Contribution Agreement ("CCA") with SIPCL (company incorporated in UK) for availing General Business Support Services (General BSS) - determination of nature of payments made to SIPCL a ......
2012 (2) TMI 75 - AUTHORITY FOR ADVANCE RULINGS
CTCI Overseas Corpn. Ltd., In re
Off-shore supplies & services - applicant being Hong Kong company – project awarded by Petronet - consortium formed with an Indian company(CINDA), to execute the project - CTCI responsible for off-shore supplies & services & CINDA for onshore supplie ......
2012 (2) TMI 74 - AUTHORITY FOR ADVANCE RULINGS
SEPCO III Electric Power Construction Corporation, In re
Off- shore supply contract – India-China Double Taxation Avoidance Convention - applicant being company of China – contract for supply of equipment to Indian company - Indian company, defined as the owner in the contract - passing of the title to t ......
2012 (1) TMI 52 - SUPREME COURT OF INDIA
Vodafone International Holdings BV. Versus Union of India & Anr.
Scope of total income - Revenue seeks to tax the capital gains arising from the sale of the share capital of CGP on the basis that CGP, whilst not a tax resident in India, holds the underlying Indian assets. - Held that:- Applying the look at test in ......
2012 (1) TMI 5 - DELHI HIGH COURT
DIRECTOR OF INCOME TAX Versus RIO TINTO TECHNICAL SERVICES
DTAA with AUSTRALIA – Fees for technical services (FTS) or inclusive contracts of technical nature - applicability of Articles 7 or 12 of the DTAA – assessee having PE in India – whether income to be construed as business income or gross receipts ......
2011 (12) TMI 195 - ITAT MUMBAI
ADIT (International Taxation) -2(2) Versus Warner Brother Pictures Inc.
Royalty for exclusive rights of distribution of Cinematographic films – India-USA Treaty assessee is a non-resident company having no PE in India – agreement with Warner Bros Pictures (India) Pvt. Ltd(WBPIPL) for grant of rights – WBPIPL deducted tax ......
2011 (12) TMI 91 - Delhi High Court
Director of Income-tax Versus Ericsson AB & Ericsson Radio System AB & Metapath Software International Ltd.
Foreign company – engaged in supply of hardware and software which is used in the business of rendering telecommunication services – validity of notice issued u/s 142 - viability of charging of interest u/s 234A and 234B on the ground that the reven ......
2011 (12) TMI 78 - AUTHORITY FOR ADVANCE RULINGS
Shell Technology India (P.) Ltd., In re
Fees for technical services - Double Taxation Avoidance Convention (DTAC) between India and Netherlands - payment made to SSSABV for business support services. - The services include invoice processing, monitoring operational execution, SOX (Business ......
2011 (12) TMI 17 - AUTHORITY FOR ADVANCE RULINGS
Perfetti Van Melle Holding BV., In re
Double taxation Agreements - Meaning of fees for technical services (FTS) - allocation of cost - the Applicant will incur cost in providing various operational and other support services for the benefit of group companies by drawing its own resources ......
2011 (11) TMI 507 - ITAT MUMBAI
Mahindra & Mahindra Ltd. Versus Assistant Director of Income-tax (IT) Range-1
Fees for technical services - reimbursements of expenses incurred for conducting market research to non resident deemed as fees for technical services – liability of TDS – assessee treated as agent of non- resident - Held that:- There was only a refe ......
2011 (11) TMI 505 - ITAT MUMBAI
International Global Networks BV Versus Deputy Director of Income-tax (International Taxation) -3(1), Mumbai
India Netherland DTAA - Taxing of interest income on income-tax refund - @ 41% OR 10% as per assessee under Article 11 of DTAA - Held that:- As decided in ACIT v. Clough Engg. Ltd. [2011 (5) TMI 562 - ITAT, DELHI] & Hapag Lloyd Container Linie GmbH v ......
2011 (11) TMI 484 - ITAT MUMBAI
Joint Director of Income-tax-OSD(IT)3(1) Versus Harvard Medical International, USA
India USA DTTA – services rendered in relation to health care - determination of nature of fees and its taxability received from Wockhardt Hospital Ltd(WHL) and MAX India Ltd(MAX) – Royalty or Fees for Included Services(FIS) or Business Profits - Hel ......