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2015 (12) TMI 840 - AUTHORITY FOR ADVANCE RULINGS

2015 (12) TMI 840 - AUTHORITY FOR ADVANCE RULINGS - [2016] 380 ITR 187 - 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 execution of “Installation Project” ? - Held that:- Since the project executed by the applicant in India for Brahmaputra continued only for 178 days in a fiscal year and as the .....

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se by the department, it is held that the income earned shall not be taxable 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. Meenakshi Sundaran, FCA For the Department : Ms Sukhvinder Khanna, CIT-DR,AAR,ND Mr. S.S. Negi, JCIT-DR, AAR, ND Mr. Sachin Dhania, DCIT-DR(AAR),ND RULING ( V. S. Sirpurkar ) .....

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obtained in AAR No.975 of 2010, the following are the questions on taxability 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 6(3) of the Income Tax Act, 1961, the Applicant can be held to have earned any income taxable in India from its activities of execution of Installation Project referred herein, .....

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