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Income Tax - Advance Ruling Authority - Case Laws

Showing 341 to 355 of 355 Records

  • 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

  • 1994 (9) TMI 349

    Whether any liability to pay income-tax in India under the Income-tax Act, 1961, read with the DTAA would arise on amalgamation of the applicant with its holding company whereby shares of an Indian company held by the company would vest in the amalgamated company ? - Whether the provisions of section 47(via) of the Income-tax Act be considered as satisfied with regard to the above scheme of amalgamation?....... + More

  • 1994 (8) TMI 304

    ... ...
    ... ... ion under section 10(5B) of the Income-tax Act, 1961, is available to the applicant. (2) On the stated facts of the case, the applicant is a "technician" within the meaning of the Explanation to section 10(5B) of the Income- tax Act, 1961.

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