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Judgment Search Results Home > Cases Phrase: citizenship constitution of india Court: authority for advance rulings Year: 2008 Page 1 of about 2 results (0.094 seconds)

Apr 30 2008 (TRI)

Knowerx Education (India) Vs. Commissioner Concerned Dit

Court : Authority for Advance Rulings

Decided on : Apr-30-2008

..... establishments. according to these provisions, where an enterprise of a state carries on business in another state through an agent, the agent will constitute permanent establishment of the enterprise depending on the fact whether it is a dependent agent or an independent agent and some other factors. as ..... of an enterprise is wholly or partly carried on. paragraph 2 specifies certain types of permanent establishments. paragraph 3 clarifies what shall not constitute permanent establishment. we are not concerned here with paragraphs 2 and 3 as the applicant is not a part of apics or ast&l ..... a contracting state" means any person who, under the laws of that state is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature, provided however, that this term does not include any ..... for the revenue advanced two new pleas. he first contended that the applicant constituted business connection in india for apics. since apics earned examination fees through this business connection, the same would be chargeable to tax in india in terms of section 9 of the act. we think otherwise. we have ..... fees, or acts as a mere conduit, but it performs a number of important functions for apics by promoting and advertising their examinations in india, collecting filled in registration forms and fees from candidates, assisting apics in selecting suitable places for conducting examinations, etc. thus there cannot .....

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Apr 30 2008 (TRI)

Knowerx Education(India) Private Limited Vs. Dit (international Taxati ...

Court : Authority for Advance Rulings

Decided on : Apr-30-2008

..... with what is known as agency permanent establishments. according to these provisions, where an enterprise of a state carries on business in another state through an agent, the agent will constitute permanent establishment of the enterprise depending on the fact whether it is a dependent agent or an independent agent and some other factors. as per paragraph 4, if the agent ..... place of business through which the business of an enterprise is wholly or partly carried on. paragraph 2 specifies certain types of permanent establishments. paragraph 3 clarifies what shall not constitute permanent establishment. we are not concerned here with paragraphs 2 and 3 as the applicant is not a part of apics or astandl. paragraph 4 and 5 are relevant for ..... this convention, the term ??resident of a contracting state ? means any person who, under the laws of that state is liable to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature, provided however, that (a) this term does not include any person who is liable to tax ..... . having realized this, the learned counsel for the revenue advanced two new pleas. he first contended that the applicant constituted business connection in india for apics. since apics earned examination fees through this business connection, the same would be chargeable to tax in india in terms of section 9 of the act. we think otherwise. we have already observed above that the income .....

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