Judgment Search Results Home > Cases Phrase: food corporations act 1964 section 18 capital of state food corporation Court: authority for advance rulings Page 1 of about 6 results (0.133 seconds)

In Re: Abdul Razak A. Meman, in Re:

Court : Authority for Advance Rulings

Reported in : (2005)195CTRAAR534

..... 91, 112, 245q(1), 245r and 245ss; finance act, 1997; municipal lawunion of india and anr. v. azadi bachao andolan and anr., (2003) 263 itr 706 (sc); cst v. indra industries, (2001) 248 itr 338 (sc); in re: emirates fertilizer training company wll, (2005) 272 itr 82 (aar); irc v. exxon corporation, 56 tax cases 237; cit v. p.v ..... ) r/w section 2(31) of the act. the taxation in force in uae is the uae tax decree of 1969 (for short the "uae decree"), which came into force on 1st jan., 1969. clause (4) of article 2 of the uae decree defines the term "person" to mean a body corporate wherever established and the expression "person liable", ..... accept the consequence (strange though it is) that similar words mean different things in the two sentences." it must be pointed out here that in the case of exxon corporation (supra), both esso and exxon were treaty subject to whom the convention admittedly applied. the question was meaningful interpretation of article xv of the agreement. in the instant case .....

M/S.Rural Electrification Corporation Ltd. Vs. Commissioner of Income ...

Court : Authority for Advance Rulings

..... were substituted, namely: an amount not exceeding (a) in the case of a financial corporation or a joint financial corporation established under the state financial corporation act, 1951 (63 of 1951), or an institution deemed under section 46 of that act to be a financial corporation established by the state government for the state within the meaning of that ..... between the profits and gains and the industrial undertaking. in the instant case, the nexus was not direct but only incidental. the industrial undertaking exported processed sea foods. by reason of such export, the export promotion scheme applied. thereunder, the assessee was entitled to import entitlements, which it could sell. the sale consideration ..... as soon as the effective source is discovered. the other two case laws on the issue of defining derived from i.e. the case of sterling food and hindustan lever ltd.(supra) the honble supreme court has followed the principle laid down by the privy council in the above case. the income .....

In Re: National Fertilizers Ltd.

Court : Authority for Advance Rulings

Reported in : (2005)193CTRAAR498

..... . it is admitted that while preparing the p&l a/c for the purpose of claiming exemption under s. 80-i of act, all income and expenditure as allocated by the corporate office and marketing division though not directly relatable to the vijaipur unit, were taken into consideration. the transfer of expenditure to vijaipur ..... between the profits and gains and the industrial undertaking. in the instant case, the nexus was not direct but only incidental. the industrial undertaking exported processed sea foods. by reason of such export, the export promotion scheme applied. thereunder, the assessee was entitled to import entitlements, which it could sell. the sale consideration therefrom ..... and hire charges of heavy vehicles respectively received by the v industrial unit. bearing in mind the principle laid down by the hon'ble supreme court in sterling foods' case, these items of income cannot be said to be 'derived from' v unit, therefore, they ought to be excluded.(sc) and pandian chemicals ltd. .....

Foster'S Australia Limited Vs. Commissioner Concerned

Court : Authority for Advance Rulings

..... to work on behalf of kpi's goodwill and associated interests. that apparatus represents kpi's property interests in new mexico, pursuant to a licensing agreement that requires kmart corporation to act on kpi's behalf.8.9. the opinion of house of lords of u.k. in the case of commissioners of inland revenue v. muller & co. ..... as already noticed, reliance was placed on the pfizer ruling. that was a case in which technical information in the form of dossier for the manufacture of certain food supplement products by the group company of pfizer in india was transferred to another company, namely, eac denmark, and the transfer of dossier took place in bangkok. ..... the asset which was the subject matter of the transfer in that case was technical information in the form of dossier in regard to the manufacture of nutritional food supplements. this authority while recording a finding that the transfer of technical information in the form of dossier amounted to transfer of a capital asset while relying .....

Foster’s Australia Limited Vs. Commissioner of Income-tax, Aurang ...

Court : Authority for Advance Rulings

..... mexico to work on behalf of kpis goodwill and associated interests. that apparatus represents kpis property interests in new mexico, pursuant to a licensing agreement that requires kmart corporation to act on kpis behalf. 8.9. the opinion of house of lords of u.k. in the case of commissioners of inland revenue vs. muller and co. ..... as already noticed, reliance was placed on the pfizer ruling. that was a case in which technical information in the form of dossier for the manufacture of certain food supplement products by the group company of pfizer in india was transferred to another company, namely, eac denmark, and the transfer of dossier took place in bangkok ..... asset which was the subject matter of the transfer in that case was technical information in the form of dossier in regard to the manufacture of nutritional food supplements. this authority while recording a finding that the transfer of technical information in the form of dossier amounted to transfer of a capital asset while relying .....

In Re: Pfizer Corporation

Court : Authority for Advance Rulings

Reported in : (2004)192CTRAAR193

..... mills co. p. ltd. v. cit, (2001) 249 itr 265; scientific engineering house p. ltd.' case, (1986) 157 itr 86 (sc) 1. the applicant, pifzer corporation panama (pc), a non-resident company, is part of the pfizer group, one of the world's largest pharmaceutical conglomerates. the applicant owned the technology information pertaining to the manufacture ..... be subject to tax in india since both parties to the transaction are non-residents.7. according to counsel, as per section 5(2) of the income-tax act (act), income of a non-resident is liable to tax in india if (a) it is received or deemed to be received in india, or (b) it ..... of nutritional food supplement product manufactured and sold by pfizer india, another group company, under the "protinex" and "dumex" trade marks. both the trade marks are registered in india. .....

Educational Institute of Vs. Commissioner of Income-tax

Court : Authority for Advance Rulings

Reported in : (1996)219ITR183AAR

..... even in the event of dissolution no member, trustee, officer of the applicant or any private individual shall be entitled to a share in its corporate assets. the tax exempt status of the applicant under the laws of usa though important has ultimately only persuasive value since the fulfilment of the requirements ..... correspondence and residential courses in michigan and other states in the following subjects : hotel-motel management, promotion, procedures, accounting, law, human relations, supervision, food service, property management, maintenance, purchasing and related classes. have the right to charge and accept dues from members of the institute and the right to accept ..... instructional resources to the in-house faculty of various institutions. (ii) whether the applicant would be entitled to exemption under section 11 of the income-tax act, 1961 2. the applicant, "educational institute of american hotel and motel association" (hereinafter referred to as "the el"), a non-resident, is a .....

In Re: Advance Ruling P. No. 10 of

Court : Authority for Advance Rulings

Reported in : (1997)224ITR473AAR

..... advantage of india's expanding infrastructure requirements, increasingly active consumer product appetites and growing new technology base as well as opportunities arising from corporate turn around strategies, privatisation opportunities, business restructuring and reorganisation strategies, among other areas. investments may be spread across the focus sectors ..... 1) 'institutional investor' means any entity other than an individual, being a natural person including but not limited to financial institution, company or corporation, government, state or political subdivision or local authority, that trustees may consider a reputable investor." 13. after a little discussion he was ..... independence of mind and judgment. 4. banking transactions will be channelled through the hongkong and shanghai banking corporations ; 5. accounting records will be maintained in mauritius in accordance with the companies act, 1984 ; 7. all statutory records, such as minutes and members' register, will be kept at .....

In Re: Cyril Eugene Pereira

Court : Authority for Advance Rulings

Reported in : (1999)239ITR650AAR

..... jain and mohini bhussry, members b. swarup, c.i.t. and h. srinivasulu, joint commissioner of income-tax appeared in person income tax act, 1961 - sections 90, 90(1), 91 and 245s(2); companies (profits) surtax act, 1964 - section 24a london county council v. attorney-general, 1900 4 tc 265; devabhaktuni durga prasad, aar no. 357 of 1997; dr. rajnikant ..... the term 'dividends' as used in this article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the state of which the company making the distribution is a resident. ..... itr 317 (aar). rafik's case [1995] 213 itr 317 (aar), takes note of the fact that the only tax imposed in the uae is on income of the corporate bodies. it further notices that though each emirate has its own income-tax decree, the decrees are similar. the judgment records (page 327) : "however, it is clear .....