Court : Authority for Advance Rulings
Decided on : Nov-30-2009
..... 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 ? ? ? ? ? ? .. ? in order to clarify the position, the applicant has filed a certificate from ..... for initial inspection of packages deemed suspicious. the recommendation of this report is to move forward with commercialization with a very targeted focus. research uncovered a company in india which is very interested in discussions about licensing. research has also uncovered two individuals who might have interest in a strategic alliance as a product representative for the drdo ..... perform the technical function himself in future, without the help of the service provider. ? the interpretation of the expression ??make available ? is found in the mou to the india-us dtaa itself. the following passage in the mou clearly brings out the meaning of that expression: ? generally speaking, technology will be considered ??made available when the person acquiring ..... within the scope of the term ??resident ? as defined in article 4 of the ??convention between the government of united state of america and the government of the republic of india for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income ? (hereinafter referred to as ??dtaa ? ). the concerned commissioner has .....Tag this Judgment!