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2005 (12) TMI 51 - AUTHORITY FOR ADVANCE RULINGS
Applicant, trust, tax resident of USA, formed for providing payment of pension and other benefits under the G.E. Pension Plan - GE sponsors a number of pension plans for the benefit of its employees – held that profits arising to Trust from the sale of portfolio investments in India will be treated as its business income – held that as the applicant is not entitled to avail of the benefits of the terms of the treaty, such business income of the applicant will be taxable in India under IT Act