28 Mar
2018

V/S IN RE: SEABIRD EXPLORATION FZ LLC

Authority For Advance Rulings

Ashutosh Chandra, Member (Revenue)[1] Seabird Exploration FZ LLC, UAE (the Applicant) filed the present application under section 245Q of the Income tax Act, 1961, and the same was admitted on 29.06.2016. The Applicant is a company incorporated under the laws of UAE, and is its t...

28 Feb
2018

V/S IN RE: FINNISH FUND FOR INDUSTRIAL COOPERATION LTD

Authority For Advance Rulings

Ashutosh Chandra, Member (Revenue)[1] The present Application for Advance Ruling has been filed by the Applicant under Section 245Q(1) of the Income Tax Act, 1961 (the 'Act') on 27.09.2012, and the same was admitted on 21.01.2015. The Applicant is a Company registered in Finland....

07 Feb
2018

V/S IN RE: HONDA MOTOR CO LIMITED

Authority For Advance Rulings

Ashutosh Chandra, Member[1] The present Application for Advance Ruling has been filed by the Applicant under Section 245Q of the Income Tax Act, 1961 (Act, for short) on 25.11.2011, and the same was admitted on 30.05.2013. The Applicant is a Corporation under the laws of Japan an...

29 Jan
2018

V/S IN RE: TEXAS INSTRUMENTS (INDIA) PVT LTD

Authority For Advance Rulings

Ashutosh Chandra, Member (Revenue)[1] The applicant, M/s. Texas Instruments (India) Pvt. Ltd. had filed an application seeking a Ruling on the questions, subsequently enumerated, on the issue of taxability in India of the salary of its employee, sent abroad for rendering services...

29 Jan
2018

V/S IN RE: HEWLETT PACKARD INDIA SOFTWARE OPERATION PRIVATE LIMITED

Authority For Advance Rulings

Ashutosh Chandra, Member[1] The applicant, M/s. Hewlett Packard India Software Operation Private Limited, had filed an application seeking a Ruling on the questions, subsequently enumerated, on the issue of taxability in India of the salary of its employees sent abroad for render...

22 Dec
2017

V/S IN RE: WORLDWIDE WICKETS

Authority For Advance Rulings

[1] The Applicant, M/s. Worldwide Wickets, Mauritius, a tax resident of Mauritius has filed application for obtaining advance ruling under section 245Q(1) of the Income-tax Act. The Applicant is the owner of shares of Star India Private Limited (SIPL) and Scorpio Television India...

08 Nov
2017

V/S PRODUCTION RESOURCE GROUP

Authority For Advance Rulings

Ashutosh Chandra, Member[1] Production Resource Group (the Applicant), is a company registered in Belgium and is engaged in the business of providing technical equipment and services for events including lighting, sound, video and LED technologies. It entered into a Service Agree...

17 Aug
2016

V/S IN RE: MERO ASIA PACIFIC PTE LTD

Authority For Advance Rulings

A.K. Tewary, Member[1] The applicant has sought ruling on the following questions:-- "(1) On the facts and circumstances of the case, whether the amounts, received/receivable by the applicant from Larsen & Toubro towards offshore supply of goods and materials are liable to tax in...

17 Aug
2016

V/S IN RE: BANCA SELLA S P A

Authority For Advance Rulings

A.K. Tewary, J.[1] The applicant Banca Sella SPA (BSS) is a banking company, wholly owned by Banca Sella Holding S.p.A. ('Holding Co.'), Italy. BSS engaged in the business of collection of savings and exercising the business of credit, in all forms, in Italy and abroad. It also p...

16 Aug
2016

V/S IN RE: TIONG WOON CONTRACTING PTE LIMITED

Authority For Advance Rulings

V.S. Sirpurkar, Chairman[1] The applicant Tiong Woon Project & Contracting (Pte) Ltd. is a tax resident of Singapore. It has raised two questions which are as under:- (i) Whether looking to the nature of activities carried on by the Applicant, which is a Singapore based company a...