Court : Authority for Advance Rulings
[By Honble Chairman] 1. In the application for advance ruling filed under section 245Q of the Income-tax Act, 1961 (for short the Act), the following facts are stated: 1.1. The applicant, Joint Accreditation System of Australia and New Zealand is a not for profit, self funding organization established under the Treaty between Government of Australia and New Zealand on 30.10.1991. It has been accorded the status of an international organization by virtue of the law made by both the nations. The applicant is a tax resident of Australia and to confirm this, a certificate issued by the Australian Revenue Authority has been enclosed. 1.2. The applicant provides accreditation to CABs (Conformity Assessment Bodies) in several countries including India. The applicant accredits organizations which provide third party certification and/or inspection services. The main function of the applicant is to accredit, following the successful assessment, those bodies considered competent and impartial to...
Tag this Judgment!Court : Authority for Advance Rulings
1. The applicant (BAGI) is a company incorporated in India on 13th July, 2007 to undertake the business of general insurance. AXA Asia Regional Centre Pvt. Ltd. (AXA ARC) is a company incorporated in Singapore and it is a part of the AXA group of companies. It acts as a Central service organization which caters to the requirements of AXA group companies in the region. The applicant entered into a Service Agreement with AXA ARC for receiving assistance such as business support, marketing information technology support services and strategy support etc. from AXA ARC. The applicant states that these services are merely advisory in nature and are procured with the intention of carrying on business in line with the best practices followed by other AXA group entities globally. 2. The applicant submits that the services provided by AXA ARC are not a one off transaction but they are meant to support the applicants functioning on a continuous basis. For providing these services no employee of A...
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Honble Chairman The applicant is a company incorporated in the Netherlands. It is engaged in the business of supplying special purpose computer software to be used in the exploration and production of mineral oils. The applicant describes it as off-the-shelf software in the sense that the software is not prepared to suit the special requirements of a customer on the basis of the order placed by the customer. The details of the software supplied are furnished at page 4 of the application. We may refer to few of them: 1. Geoframe Run Time which is the entry point for geologists wanting to run various geoframe modules. 2. Geoframe Data Monitor which is used to access the functions and utilities for seismic map and interpretation functions. 3. ISEX suit with all functionalities. It is described as a geoframe seismic interpretation module. 4. ASAP (Automatic Surface Air Picking) which allows the tracking of one or more events within a seismic volume. 5. Variance Cube which highlights the fa...
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