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2009 (4) TMI 18 - AUTHORITY FOR ADVANCE RULINGS
Can a partnership firm formed between the applicant and an entity in Canada be granted status of ‘firm’ if it satisfies conditions u/s 184 – Held, yes - tax liability of the partnership in India, shall be @ 30 per cent plus applicable surcharge and cess in accordance with Finance Act – residential status of the firm is a question of fact, which can be determined by the AO at the relevant point of time - share of the partners in firm shall not be included in the total income of such partners