Court : Authority for Advance Rulings
Decided on : Mar-18-1997
Reported in : (1999)237ITR230AAR
..... india-mauritius treaty. the following commentary in respect of paras. 4 and 5 of the other models (which correspond to paras. 5 and 6 of the indian treaty under consideration here) clearly elucidates the principles behind these provisions : "para. 31. [principle] it ..... fact an authority to conclude contracts, even if not under private law (the law of contracts), but at all events within the meaning underlying article 5. corresponding clarification is already to be found in some dtcs (cf., e.g., germany's dtc with malaysia, para. 3(b) prot. re article 6), ..... in this case are based upon the model conventions evolved by the oecd, un and usa. there are of course some variations but a comparative reading will leave no doubt that several observations in the commentary on the un model will be equally apposite even for the interpretation of the ..... appellant/petitioner/plaintiff: o.p. vaish and tapas misra, advs.and ajay vohra, chartered accountant 1. this is an application under section 245q(1) of the income-tax act, 1961 ("the act"). the applicant is tvm limited, a company incorporated in mauritius on may 23, 1995. it is stated that the effective place ..... of management of the company is in mauritius and that, therefore, the applicant is a non-resident under section 6 of the act.2. the applicant (tvm) has five share holders whose names and extent of shareholding are set out below : *what appear above are .....Tag this Judgment!