Judgment Search Results Home > Cases Phrase: indian museum act 1910 preamble 1 indian museum act 1910 Sorted by: recent Court: authority for advance rulings Page 1 of about 5 results (0.126 seconds)

In Re: Abc Ltd.

Court : Authority for Advance Rulings

Reported in : (2007)289ITR438AAR

..... dossier containing the know-how and technical information, it was held that the transfer of technology information in the form of a dossier was transfer of a capital asset and that on the indian company entering into agreement with the foreign company of denmark for early termination of the licence to manufacture the products, technical information reverted to the applicant and that those facts showed that the ..... under section 9(1)(i), explanation to 9(1)(i)business connection--applicant, a company incorporated in switzerland and a tax resident thereof had entered into an agreement with an indian company for manufacturing and supply of turbo charges for vehicle and for that propose it proposed to establish indian subsidiary to be incorporated under indian companies act, and assigned its rights, interest and obligations in agreement on agreed consideration to be paid to applicant company in instalments. ..... clauses of the agreement exhibit - 2 which are relevant for the present discussion: (1) the preamble of the agreement recites, inter alia, that as a result of long experience in the business of design, development and manufacture of trucks and passenger vehicles for the indian and overseas markets, xyz ltd. ..... section the preamble to the deed of assignment says ..... (c) of the preamble mentions that the ..... the preamble of the exhibit-4 states that the assignor (applicant) is engaged in the business of design, development and manufacture of engine boosting systems for the worldwide market and .....

Abc Ltd. Vs. Cit-i Pune

Court : Authority for Advance Rulings

..... activity carried out through a broker, general commission agent or any other agent having an independent status, if such broker, general commission agent or any other agent having an independent status is acting in the ordinary course of his business: provided further that where such broker, general commission agent or any other agent works mainly on behalf of a non-resident (hereinafter in this proviso ..... "business connection" which is in the following terms:- [explanation 2 for the removal of doubts, it is hereby declared that "business connection" shall include any business activity carried out through a person who, acting on behalf of the non-resident,- (a) has and habitually exercises in india, an authority to conclude contracts on behalf of the non-resident, unless his activities are limited to the purchase of goods or merchandise ..... person responsible for paying to a non-resident, not being a company, or to a foreign company, any interest or any other sum chargeable under the provisions of this act (not being income chargeable under the head "salaries") shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by the ..... the agreement exhibit-2 which are relevant for the present discussion:- (1) the preamble of the agreement recites, inter alia, that as a result of long experience in the business of design, development and manufacture of trucks and passenger vehicles for the indian and overseas markets, xyz ltd. .....

Cholamandalam Ms General Insurance Co. Ltd. Vs. Commissioner of Income ...

Court : Authority for Advance Rulings

..... services is defined to mean (a) to introduce to the recipient company potential business from and provide access to clients, and business contacts for the korean business in india; (b) to assist the recipient in developing insurance products for the indian market including specific policy wordings, terms and conditions and advice and expertise on pricing technique; (c) to furnish the recipient with such expertise necessary to establish and develop the business including actuarial and accounting ..... discussed the question whether reimbursement of a part of expenses incurred on research to the assessee a non-resident company by its subsidiary constitutes income of the said non-resident company the agreement inter alia required the indian subsidiary to pay to the assessee company a proportionate part of the costs and expenses (including salaries and research and development expenditure) incurred by the assessee company for the acquisition and development of information, processes and ..... whereas, according to the learned counsel for the revenue, it is in the nature of such consideration within the meaning of section 9(1)(vii) of the act read with article 13.4 of dtaa, the applicants contention is that it represents partial reimbursement of salary cost borne by the provider company and nothing more. ..... in the preamble it is stated that for developing the korean business, the recipient is interested in taking a person who has knowledge of korea, korean language and korean insurance business .....

In Re: Advance Ruling P. No. 10 of

Court : Authority for Advance Rulings

Reported in : (1997)224ITR473AAR

..... board of directors ("the board"), will be guided and monitored in three different ways : (i) the im will constitute an investment committee with four representatives nominated by the american company and three including the chairman nominated by the indian financial service company which will recommend (acting by majority vote) portfolio investments for approval by the board but with a right of veto to the american company. ..... by a letter dated june 27, 1996, the applicants have indicated an insertion in the preamble of the c. a. ..... income", 'part of relevant income' and 'beneficiaries', respectively), tax shall be charged on the relevant income or part of relevant income at the maximum marginal rate : (i) none of the beneficiaries has any other income chargeable under this act exceeding the maximum amount not chargeable to tax in the case of an association of persons or is a beneficiary under any other trust ; or (ii) the relevant income or part of relevant income is receivable under a trust declared by any person by will ..... in cases to which the provisions of chapter xii or chapter xiia or sub-section (1a) of section 161 or section 164 or section 164a or section 167b of the income-tax act, 1961 (43 of 1961) (hereinafter referred to as income-tax act), apply, the tax chargeable shall be determined as provided in that chapter or that section, and with reference to the rates imposed by sub-section (1) or the rates as specified in that chapter or section, as the case may be : provided .....

In Re: P. No. 18 of 1995

Court : Authority for Advance Rulings

Reported in : (1999)238ITR575AAR

..... and circumstances of the case (where the applicant joint venture has business operations only in relation to india) the deduction of a head 'office expenditure' would be subject to limits laid down in section 44c of the income-tax act, 1961 (iii) whether the entire business income of the applicant accruing or arising from this contract would be assessable in india or only that part of it which is reasonably attributable to operations in india (iv) whether and to what extent services ..... two companies that as and from the september 1, 1988, they had constituted themselves together as a joint venture "for the purpose of bidding for and carrying out engineering projects in india" in various fields enumerated in the preamble and provided that "neither party shall carry on its own separate business for its sole benefit in india without the prior written consent of the other". ..... it is, therefore, urged that the tax deductions already made more than cover the applicant's possible tax liability in respect of the indian currency payments and that, therefore, even if no refunds are directed out of the tax deductions already made, at least further deduction of tax at source on such payments should be stopped.20. ..... it will be difficult for us, without more data, to estimate the exact percentage of taxable income embedded in the payments made in indian currency or the exact percentage of the profits embedded in the foreign currency payments that may be attributable to operations in india. .....