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In Re : Tiong Woon Project & Contracting (Pte) Limited

2015 (12) TMI 840 - AUTHORITY FOR ADVANCE RULINGS

Taxability of income - Whether activities carried on by the Applicant, which is a Singapore based company and a non-resident as per provisions of section 6(3) the Applicant can be held to have earned any income taxable in India from its activities of .....

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t Establishment of the applicant cannot be constituted in India for the FY 2012-13 as per the provisions of Article 5.3 of the India-Singapore DTAA. Hence, the business profits accruing or arising to the applicant by way of the execution of the proje .....

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ble in India. On this basis, the application is directed to be disposed of. - A.A.R. No. 1602 of 2014 - Dated:- 30-11-2015 - Mr V.S. Sirpurkar, Chairman, Mr. A. K. Tewary, Member ( Revenue ) And Mr. R.S. Shukla, Member (Law) For the Applicant : Mr. K .....

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andan Street, Singapore. 2. The Applicant is engaged in the business of heavy lifting and erection and installation of heavy equipments such as boilers, coke drums, fractionators, generators, chimneys, etc., for large projects at the project sites. I .....

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ility of certain projects executed by the Applicant in India. 4. The questions posed are:- 1. Whether looking to the nature of activities carried on by the Applicant, which is a Singapore based company and a non-resident as per provisions of section .....

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ove question is affirmative, how the total income of the Applicant should be computed as per the provisions of the Income Tax Act, 1961? 5. In the application, it is stated, the applicant completed their installation project, which is covered by Arti .....

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erms of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and Singapore. It is the claim of the applicant that they do not have any Permanent Establishment (PE) in India. It is, further, their claim that since this installatio .....

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