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2012 (8) TMI 743 - AAR - Income TaxIndia Srilanka DTAA - Capacity Sales Agreement - whether the amounts payable by the applicant to SLT (Sri Lanka) under the terms of the Agreement would be in the nature of 'royalty' ? - Held that:- As taking several adjournment by the assessee and unable to submit the Consortium agreement, thus without understanding the right of the grantor of the right to the applicant, it would not be possible to rule on the questions raised satisfactorily - as it would be hazardous to venture to rule on the questions formulated without understanding the contents of the document and comprehending the rights available to SLT decline to rule on the questions formulated and close this application leaving it to the applicant to raise its contentions before the Assessing Officer - against assessee.
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