Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2014 Year 2014 This

Advance Ruling - The stage at which the permanent establishment ...

Income Tax

April 29, 2014

Advance Ruling - The stage at which the permanent establishment came into existence is a mixed question of fact and law. The Authority has not considered this question in view of its conclusion that Linde and Samsung had constituted an Association of Persons which was a tax resident entity in India for the purposes of the Act. - HC

View Source

 


 

You may also like:

  1. Question of law or facts - on the facts and circumstances of the instant case, as the plea of limitation turns on facts and as it is clearly not a pristine question of...

  2. Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

  3. Scope of advance ruling (AAR) - The ruling is sought on two questions: GST applicability on electricity produced from solar panels and on services provided by KSEB. -...

  4. Scope of advance ruling - AAR obtained the ruling by fraud or suppression of facts - misdeclaration of facts - search proceedings were initiated - appellant was also...

  5. Maintainability of application - in any case the definition of advance ruling does not permit making of an application in relation to the supply of services already...

  6. Scope of Advance Ruling - Validity of Ruling dated 20/01/2021 - The Authority for Advance Ruling (AAR) declared the advance ruling void ab initio under section 104 of...

  7. Scope of Advance Ruling application - zero-rated supply or a Normal supply - export of service - The Advance Ruling Authority should have refrained from passing any...

  8. Manual filing of applications for Advance Ruling and appeals before Appellate Authority for Advance Ruling

  9. TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and...

  10. Existence of Permanent establishment - pierce the veil - there is interlacing of activities and interlocking of funds between the assessee and its Indian subsidiary in...

  11. Scope of Advance Ruling application - Exemption from GST - As the question posed by the applicant is related to supplies undertaken by them prior to the date of filing...

  12. Validity of Advance Ruling application obtained - matter was alreay pending before DG GST Intelligence - suppression of material facts or not - Taxpayer has not brought...

  13. Scope of the Advance Ruling - Whether the matter (case) was pending - Merely because an officer of customs contemplates that a question may arise, does not mean that the...

  14. 100% EOU - Extended period of limitation - escapement of assessment u/s 14 of the Customs Act, 1962 - The question of limitation is a mixed question of fact and law. It...

  15. Scope of Advance Ruling application - supplies undertaken prior to the date of filing of the application for advance ruling - The scope of the ruling for Authority for...

 

Quick Updates:Latest Updates