Recent Decisions - Pranav Sayta. Contents. Ishikawajima-Harima Heavy Industries Co Ltd - Turnkey Contracts Sony India Private Ltd – Transfer Pricing Dresdner Bank – Payments to Head Office Fidelity Northstar Fund – Foreign Institutional Investors.
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IHI filed an application before the Authority for Advance Ruling (‘AAR’) to determine the taxability of offshore supply and offshore services
No indication on profit attribution
IHI filed a Special Leave Petition (‘SLP’) with the Honourable Supreme Court of India (‘Supreme Court’) against the ruling issued by the AAR
While claiming relief under the Agreements for Avoidance of Double Taxation between India and USA / Canada (‘Treaty’):