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Judgment Search Results Home > Cases Phrase: state agricultural credit corporations act 1968 section 25 reserve fund Sorted by: old Court: authority for advance rulings Page 1 of about 14 results (0.152 seconds)

Dec 19 2008 (TRI)

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

Court : Authority for Advance Rulings

..... company (iii) a banking company (iv) a co-operative bank other than a primary agricultural credit society or a primary co-operative or agricultural and rural co-operative bank (v) a housing finance company; and (vi) any other financial corporation including a public company. the main business of these eligible entities is still to provide ..... examine whether the applicant is an eligible entity for the deduction under section 36(1)(viii) of the act. the eligible entity has been stated to be a financial corporation which includes, as per the definition in the section, a public company and a government company. as per the explanation appended to section 36 ..... as the transferee enterprise) for the purpose of operating and maintaining the infrastructure facility on its behalf in accordance with the agreement with the central government, state government, local authority or statutory body, the provisions of this section shall apply to the transferee enterprise as if it were the enterprise to which .....

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Mar 27 1996 (TRI)

In Re: Advance Ruling A. No. P-12 of

Court : Authority for Advance Rulings

Reported in : (1997)228ITR61AAR

..... and the interest earnings from the applicant's ira investment through sis in a non-resident non-repatriable rupee deposit scheme for nris will be exempt from all corporate and individual taxes in india (ii) the ira withdrawals by the applicant will be tax exempt income in india (iii) the gifts made by the applicant from ..... a period of about ten years and on the assumption that the ira account continues till then without the applicant having withdrawn the entire amounts standing to his credit in that account. the second question raised by the applicant is answered accordingly.9. this takes one to the consideration of the first question raised by the ..... applicant entered into an individual retirement arrangement ("ira") with sis, a banking institution, and a subsidiary of an american bank.under section 408(a) of the united states internal revenue code, the ira is a trust account of which sis is the custodian. broadly speaking, contributions made to the ira by employee-members are tax deferred .....

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May 17 1996 (TRI)

Decta Vs. Commissioner of Income-tax

Court : Authority for Advance Rulings

Reported in : (1999)237ITR190AAR

..... by the oda. in 1991, the control of decta was passed from the oda to the "crown agents for overseas government and administrations", a statutory uk corporation with worldwide activities in the field of industrial and economic development, inspection and quality assurance, and economic, financial and technical consultancy services. decta is still sponsored ..... the reserve bank of india (rbi) to open an account called "qa.22a/c" with the standard chartered bank subject to the following conditions : (1) credits to the account will be by way of foreign inward remittances and consultation charges received from indian companies. (a) for making payment of hotel bills in india for ..... (c) certified copy of the audited final accounts of the office in india; and (d) annual report of the work done by the representative in india, stating therein the details of actual export or import, if any, effected during the period in respect of which the representative had rendered liaison services.7. decta was also .....

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Aug 14 1996 (TRI)

In Re: Advance Ruling P. No. 10 of

Court : Authority for Advance Rulings

Reported in : (1997)224ITR473AAR

..... a business of "providing financial assistance and money market operations". he says that its activities are analogous to those of organisations like the industrial credit and investment corporation of india (icici) or the industrial development bank of india (idbi) which return, and are assessed on, income from business and of ..... 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 willing also to drop ..... , privatisations and the like. the fund will only invest in projects that at the time of the investment comply with all relevant indian state and central government legislation regarding environmental protection, and such guidelines on environmental protection and social and rehabilitation issues which may be adopted by the .....

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Mar 18 1997 (TRI)

Tvm Ltd. Vs. Commissioner of Income-tax

Court : Authority for Advance Rulings

Reported in : (1999)237ITR230AAR

..... 'person' includes an individual, a company and any other entity, corporate or non-corporate, which is treated as a taxable unit under the taxation laws in force in the respective contracting states ; . . . . (g) the terms, 'enterprise of a contracting state' and 'enterprise of the other contracting state' mean, respectively, an industrial, mining, commercial, plantation or agricultural enterprise or similar undertaking carried on by a resident of ..... a contracting state and an industrial, mining, commercial, plantation or agricultural enterprise or .....

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Jul 16 1997 (TRI)

Dljmb Mauritius Investment Vs. Commissioner of Income-tax

Court : Authority for Advance Rulings

Reported in : (1997)228ITR268AAR

..... mauritius only and not in india ?" 2. the background in which these questions have been raised may now be briefly stated. dlj is stated to be a leading investment and merchant bank which serves institutional, corporate, governmental and individual clients both domestically and internationally. it is a holding company which conducts its business through various subsidiaries. ..... tax ; " 9. it is pointed out, on behalf of the department, that all the various entities which are proposing the invest their monies are all corporations or partnerships located in the usa. they could have directly invested those monies in india and if they had done so they might not have been able to ..... three principal operating groups for the year ended march 31, 1995, is said to be 2088.77 million u.s. dollars. the applicant-company, as already stated, has been organised as a limited liability company in mauritius. the two subscribers to its memorandum are tiger nominees limited and orchin nominees limited, each of .....

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Dec 04 1998 (TRI)

In Re: Application No. P-16 of 1998

Court : Authority for Advance Rulings

Reported in : (1999)236ITR103AAR

..... law relating to companies formerly in force in any part of india (other than the state of jammu and kashmir and the union territories specified in sub-clause (iii) of this clause ; (ia) a corporation established by or under a central, state or provincial act ; (ib) any institution, association or body which is declared by ..... (acquisition and transfer of undertakings) ordinance, 1980, promulgated by the president on the 15th april, 1980. the ordinance was also considered necessary for providing larger credit to priority sectors, for establishing a more effective and meaningful direction and control over the operations of these banks and also for making these banks an integral ..... argument was countered by saying that a foreign banking company is not permitted to carry on business in the agricultural sector. that may be so. but a nationalised bank has to open branches in the agricultural and semi-urban sectors even though such branches may not be profitable. the overriding idea is to provide .....

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May 19 1999 (TRI)

In Re: Cyril Eugene Pereira

Court : Authority for Advance Rulings

Reported in : (1999)239ITR650AAR

..... which is for avoidance of double taxation.35. under article 6 of the double taxation avoidance agreement, income from immovable property including income from agriculture or forestry is to be taxed only in the country where such immovable property is situated. the owner of the property may be a resident ..... force in the respective contracting states ; (f) the term 'company' means any body corporate or any entity which is treated as a company or body corporate under the taxation laws in force in the respective contracting states ; (g) the terms 'enterprise of a contracting state' and 'enterprise of the other contracting state' mean respectively, an enterprise ..... shall have the meaning which it has under the law of the contracting state in which the property in question is situated. the term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property .....

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Mar 07 2001 (TRI)

In Re: Xyz/Abc, Equity Fund

Court : Authority for Advance Rulings

..... a mine, an oil or gas well, a quarry or any other place of extraction of natural resources;. (h) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on;. (i) a building site or construction or assembly project or supervisory activities in connection therewith, where such site ..... , bank association or partnership, constituted or carrying on business in any part of the world, trust, scheme sponsored by a trust, mutual fund, investment corporation or collective investment scheme in any part of the world, currencies and any rights and interests to or in any of the foregoing (whether issued or to ..... treated as an independent agent. therefore, investment adviser cannot be regarded as a "permanent establishment" of the applicant company. having regard to the facts as stated by the applicant it may be held that the activities done by the investment adviser cannot be converted into "permanent establishment" of the applicant-company in india .....

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Nov 29 2004 (TRI)

In Re: Morgan Stanley and Co.

Court : Authority for Advance Rulings

Reported in : (2005)193CTRAAR161

..... or merchandise from which he regularly delivers goods or merchandise for or on behalf of the enterprise; or (c) he habitually secures orders in the first-mentioned state, wholly or almost wholly for the enterprise itself or for the enterprise and other enterprises controlling, controlled by, or subject to the same common control, as that ..... acquired large block of shares in indian companies and that indicated a large systematic activity for making profits. transactions of this magnitude in furtherance of the object stated in its memorandum could be nothing other than business and the proceeds of sale of shares in india would amount to business receipts and not capital gains. ..... be treated in isolation and that profit/loss from both the activities should be given similar treatment in order to maintain tax consistency, the derivatives, it is stated, are in the nature of capital assets; the gains thereon would be liable to taxation as "capital gains" as provided in article 14 of the treaty. .....

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