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Judgment Search Results Home > Cases Phrase: calcutta police act 1866 Sorted by: old Court: authority for advance rulings Year: 2011 Page 1 of about 2 results (0.037 seconds)

Feb 22 2011 (TRI)

Transworld Garnet Company Limited Vs. Director of Income-tax (internat ...

Court : Authority for Advance Rulings

Decided on : Feb-22-2011

..... minerals to deduct tax at the rate equal to 21.115 per cent on long-term capital gains. 2. the applicant draws attention to section 48 of the income tax act 1961(act) which reads as under: ??mode of computation. 48 the income chargeable under the head ??capital gains ? shall be computed, by deducting from the full value of the ..... treatment under article 24 of the india-canada tax double taxation avoidance agreement ( ??dtaa ??)? (2) whether in computing the capital gains, deduction is admissible under section 48 of the act on account of the following expenses incurred in connection with transfer of shares? fees for valuation of business, professional fees for advice in connection with transfer, legal expenses, fees for ..... valuation of business, professional fees for advice in connection with transfer, legal expenses, fees for escrow account, travel and hotel charges. it is contended that section 48 of the act provides that expenditure incurred wholly and exclusively in connection with transfer will be deducted from the full value of consideration from computation of capital gains. as these expenses are allowable ..... states. given the above, the capital gains arising to tgbc on transfer of its shareholding tgi is taxable in india in accordance with the provisions of the income-tax act. the applicant submits that it wishes to invoke the provisions of article 24 of the india-canada dtaa providing protection against discrimination against nationals of the other contracting state. .....

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May 03 2011 (TRI)

Abc International Inc. Usa Vs. Director of Income-tax(international Ta ...

Court : Authority for Advance Rulings

Decided on : May-03-2011

..... of exchange or promissory notes pertaining to its indian group entities is liable to tax in india as per the provisions of income-tax act, 1961 ( ??the act ??) or under the provisions of double taxation avoidance agreement between india and united states of america (dtaa)? 2. in case the above ..... a bill of exchange should be understood differently for the purpose of testing the transaction put forward in the anvil of the indian income-tax act with particular reference to this authority ??s jurisdiction. it for the executive govt. and the legislature to decide whether it is necessary or ..... services and securities ltd. v. cit (258 itr 496) while dealing with the definition of interest in the act, after taking note of the expanded nature of the definition, concluded ??even in cases where there is no relationship of debtor and creditor or borrower ..... a later date. but that consideration cannot be treated as payment of interest upfront in the context of the law merchant and the negotiable instruments act and the commercial and legal implications of a discounting of an instrument. 13. the decision of the high court of madras in viswapriya financial ..... parts with all rights, title and interests in the bill and its proceeds. ? their lordships also referred to section 50 of the negotiable instruments act dealing with the effect of an endorsement, to notice that the property in the instrument then passes to the endorsee. the observation in halsbury ??s .....

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