2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...

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Tax Avoidance: E-Trade• Bombay High Court in IAL Shipping Agencies : In context ofseparate-legal entity approach, BHC has observed that: "It cannot besaid that the assessee company and the UK company, which wereunder the same management, are the same entity. Both of them areseparate companies incorporated under the respective statutes oftheir countries and merely because the shareholding is held by thesame group, the companies do not loose their separate entitles andthe conclusion of the assessing officer that they cannot act asprincipals and agents is bad in law especially when it is not indispute that the assessee companies were incorporated in Indiawhereas the said IAL Container Lines (UK) Ltd. was incorporatedunder the provisions of the <strong>Com</strong>panies Act prevailing in UK. The UKcompany was already carrying out its activities of shipping businessin India prior to the incorporation of the assessee "" …..
Tax Avoidance: E-Trade• Supreme Court decision in the case of Mrs Bacha FGuzdar (27 ITR 1), which held that the company is a legalentity, separate and distinct from its shareholders andthere is nothing in the Indian law to warrant theassumption that a shareholder who buys shares buys anyinterest in the property of the company
Page 1 and 2: ICAI Committee on International Tax
Page 3 and 4: Outline• Mumbai Bench of ITAT in
Page 5 and 6: Outline• Taxability of Offshore S
Page 7 and 8: Tax Avoidance: SC AzadiBachao• Th
Page 9 and 10: Tax Avoidance: E-Trade• E*Trade M
Page 11 and 12: Tax Avoidance: E-Trade• The AAR r
Page 16 and 17: Tax Avoidance: STAR AAR…..Be that
Page 18 and 19: Tax Avoidance: P&H Porrits..• On
Page 20 and 21: Tax Avoidance: VodafonecaseIst Roun
Page 22 and 23: Tax Avoidance: Vodafone• Facts:
Page 24 and 25: Tax Avoidance: Vodafone BHCInitial
Page 26 and 27: Tax Avoidance: Vodafone BHCInitial
Page 28 and 29: Tax Avoidance: Developmentsto look
Page 30 and 31: Changes in DTC in FTS andServices t
Page 32 and 33: Bang ITAT Mondial Orient• AAR Con
Page 34 and 35: Delhi ITAT Lucent ServicePEHeld: A
Page 36 and 37: BHC in Krupp GmbH• The learned Co
Page 38 and 39: BHC in Krupp GmbH• Further refer:
Page 40 and 41: Bang ITAT in CGI Info….….wherei
Page 42 and 43: Nathpa Jhakri Joint Venture vsACIT
Page 44 and 45: BHC in InformationArchitects• In
Page 46 and 47: Contd Mum ITAT Royalty….25. It is
Page 48 and 49: DHC Royalty Sahara…• Appellant/
Page 50 and 51: Mum ITAT Ashapura BauxiteTesting In
Page 52 and 53: AAR FICCI - INDIA USDTAA• Held "
Page 54 and 55: AAR in HMS Real Estate• HMS real
Page 56 and 57: AAR in Airport Authority case• Th
Page 58 and 59: AAR Software : AirportAuthority cas
Page 60 and 61: AAR Seagate: India SingaporeDTAA•
Page 62 and 63: AAR Seagate: India SingaporeDTAA•
Page 64 and 65:
Delhi ITAT ParasrampuriaSynthetics
Page 66 and 67:
AAR IN Royal Bank ofCanada• There
Page 68 and 69:
Kar High Court Illions case• Kar
Page 70 and 71:
“Technopromexport”HELD11. In vi
Page 72 and 73:
“Technopromexport”HELD• As ob
Page 74 and 75:
AAR in Hyundai and MistubishiAOP Co
Page 76 and 77:
Mumbai ITAT in Valentine 3taxmann.c
Page 78 and 79:
Delhi ITAT Pioneer India USADTAA 1
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Thank YouKapil Goelcakapilgoel@gmai
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2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...

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