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Income Tax - Advance Ruling Authority - Case Laws

Showing 341 to 360 of 362 Records

  • 1996 (10) TMI 485

    Whether the applicant will qualify as a technician in accordance with section 10(5B) of the Act ; and accordingly. - Whether, the taxes paid by the employer of the applicant would be exempt from taxation under section 10(5B) of the Act, for a period of fortyeight months commencing from the date of arrival in India ?....... + More


  • 1996 (8) TMI 544

    ... ...
    ... ... India will be liable to tax 12.5 . Question No. 2(c) The capital gains arising from the sale of movable assets will be exempt from income-tax in India. Question No. 3 In view of the affirmative answer to Question No. 1, this question does not arise.


  • 1996 (8) TMI 538

    Whether, on the facts and in the circumstances of the case, exemption under section 10(5B) of the Income-tax Act, 1961, would be available to the applicant ? - Whether, on the facts and in the circumstances of the case, the applicant would be considered as a technician for the purpose of section 10(5B) of the Income-tax Act, 1961 ?....... + More


  • 1996 (8) TMI 512

    Application of investor company (IC) - (a) Whether in view of the provisions of India-Mauritius double tax avoidance agreement, can it be construed that the applicant does not have a permanent establishment (PE) in India ? - (b) Whether the applicant be liable to tax in respect of the management fees received from the CT ? - (c) Whether the applicant be liable to tax in respect of the carried interest received from the CT ? - (d) Whether there be....... + More


  • 1996 (6) TMI 346

    ... ...
    ... ... the First Schedule to the Finance Act, 1995. The Authority does not express any opinion about the net profits of the applicant-company from the local operations and leaves the question open to be agitated by the applicant in appropriate proceedings.


  • 1996 (5) TMI 428

    ... ...
    ... ... to US 5,295,756 by 'C' to 'B' as a consideration for granting the licence and right to 'IC', a company in which 'CM' has 51 per cent. equity holding, to use the trade mark in India is liable to Indian tax ?" Yes


  • 1996 (5) TMI 385

    The amount of contribution received/ receivable to recover part of the cost of the technical assistance provided by the applicant under the provisions of its aid programme to the companies assisted by it in India is not an income of the applicant under the provisions of the Income-tax Act and not chargeable to tax. - No amount of contribution received/ receivable to recover part of the cost of the technical assistance provided by the applicant un....... + More


  • 1996 (4) TMI 491

    Whether based on the stated facts of the case, the amounts received by the applicant outside India are taxable in India ? - Whether based on the stated facts of the case, the nature of activities performed by the applicant in India, constitute a permanent establishment (PE) in India as per the provisions of article 7 of the Double Tax Avoidance Agreement (DTAA) between India and Malaysia ? ....... + More


  • 1996 (2) TMI 567

    ... ...
    ... ... ng or accruing from the sources mentioned in the question would not be taxable. Question (ii) Since the answer to the first question is in the affirmative and in favour of the applicant, the second question becomes academic and need not be answered.


  • 1996 (2) TMI 561

    ... ...
    ... ... raised in Application No. P 11 of 1995. Ruling The revenues earned by the applicant from the contracts entered into with ABC, Singapore during the previous year ended on 31st March, 1995 would not be liable to tax in India, as it had no PE in India.


  • 1996 (2) TMI 560

    ... ...
    ... ... cant and the subsidiary referred to above. Question B The extent of the income deemed to accrue or arise in India will depend on the actual working of the applicant and the subsidiary. Thus, this question cannot be answered in a hypothetical manner.


  • 1996 (2) TMI 559

    ... ...
    ... ... (1). The application is, therefore, rejected as not maintainable and in view of this conclusion, the Authority is not called upon to give any ruling on the questions posed by the assessee. The application is, therefore, rejected as not maintainable.


  • 1995 (12) TMI 394

    ... ...
    ... ... the purpose of investment in this manner can only be for the purpose of avoidance of income-tax. For the reasons discussed above, the Authority rejects the applications under clause (c) of the proviso to section 245R(2) of the Income-tax Act, 1961.


  • 1995 (9) TMI 376

    Whether the consideration receivable under the agreements entered into between the applicant and X is chargeable to tax under the Income-tax Act, 1961? - Whether the considerations receivable under the aforesaid agreements are taxable as fees for technical services under article 13 of the Agreement for Avoidance of Double Taxation and Prevention of fiscal evasion with respect to taxes on income and capital gains with the United Kingdom of Great B....... + More


  • 1995 (8) TMI 315

    ... ...
    ... ... them under sections 28 to 44C or section 57 of the Act) will be assessable to tax and that such net amount will be assessable not at the rate of 30 per cent. but at the rate of income-tax applicable to such income in the hands of a foreign company.


  • 1995 (8) TMI 312

    Whether on the stated facts of the case, exemption under section 10(5B) of the Income-tax Act, 1961, would be available ? - Whether on the stated facts, I would be considered as a technician for the purpose of section 10(5B) ?....... + More


  • 1995 (8) TMI 305

    Whether the applicant will not be liable to pay income-tax in India on the income from the three categories of assets set out in the question? - Whether the interest on the fixed deposit will be liable to income-tax in India if it is received, or the right to receive it is exercised, in India? - Whether if the factual foundations mentioned in the question are fulfilled, the transaction will not attract any income-tax in India? - Whether no income....... + More


  • 1995 (5) TMI 266

    Whether the applicant is liable to interest under sections 234B and 234C in respect of tax paid vide cheque No. xxxxx xxxxx dated March 10, 1994?....... + More


  • 1994 (12) TMI 329

    Whether the applicant, an individual residing in the U. A. E. is entitled to claim the benefit of the provisions of the tax treaty entered into between India and U. A. E. ? - Whether in terms of article 13(3) and article 4 of the tax treaty between India and U. A. E., the applicant, an individual Indian national residing in U. A. E., is liable to capital gains tax on the transfer effected in India of movable assets in the nature of shares, debent....... + More


  • 1994 (12) TMI 326

    Whether the applicant is liable to income-tax on the sum received by him on July 6, 1992, towards arrears of rent for the period up to March 31, 1992, in the assessment year 1993-94?....... + More


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