Subscription   Feedback   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Articles Highlights TMI Notes SMS News Newsletters Calendar Imp. Links Database Experts Contact us More....
Extracts
Home List
← Previous Next →

IN RE: MAGOTTEAUX INTERNATIONAL S.A., BELGIUM,

2015 (8) TMI 457 - AUTHORITY FOR ADVANCE RULINGS

Taxability of the income generated by fees for technical services (FTS) - applicant relies on DTAA between India and Belgium and also the DTAA between India and Portugal and, since the Portugal Treaty goes beyond the Treaty in between India and Belgi .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ted on account of the earned interest. There is no statement found in the whole application that the applicant does not have an income from royalty or from interest. In that view, Shri Piyush Kaushik made a categorical statement before us that he is .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

me.

In our opinion, therefore, this cannot be seen as a device to avoid the tax. In that view we would prefer to admit the application. We make it clear that the Department will be free to take such action as is permissible by law in respe .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ty Commissioner and Ms. Anusha Khurana, Additional Commissioner for the Department. RULING 1. Heard Shri Piyush Kaushik on behalf of the applicant and Shri Kanv Bali and Ms. Anusha Khurana on behalf of the Revenue. We have perused the application. Th .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

Portugal. According to the applicant, since the Portugal Treaty goes beyond the Treaty in between India and Belgium as per the protocol the applicant will be entitled to take the benefit of Portugal Treaty also. 2. The Revenue, however, seriously op .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

er claiming nil income. During the assessment of proceedings, it was found that though the applicant had claimed the whole income on account of FTS. In fact, the applicant had earned some income on account of royalty and as also interest income. It i .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

 

 

 

 

 

what is new what is new
  ↓     bird's eye view     ↓  


|| Home || Acts and Rules || Notifications || Circulars || Schedules || Tariff || Forms || Case Laws || Manuals ||

|| About us || Contact us || Disclaimer || Terms of Use || Privacy Policy || TMI Database || Members || Site Map ||

© Taxmanagementindia.com [A unit of MS Knowledge Processing Pvt. Ltd.] All rights reserved.

Go to Mobile Version