Saudi Arabian Oil Company In Re vs nan

Authority: Authority for Advance Rulings Date: 2018-05-31 Section: 245Q(1), 9(1)(b) Acts: Income Tax Act 1961, Double Taxation Avoidance Agreement between India and Kingdom of Saudi Arabia Result: Appellant Citation: (2018) 102 CCH 0056 IAAR : (2018) 167 DTR 0185 (AAR) : (2018) 405 ITR 0083 (AAR) Justices: R S SHUKLA, IN-CHARGE CHAIRMAN & ASHUTOSH CHANDRA, MEMBER (REVENUE) Appeal No: AAR No. 25 of 2016
Whether the proposed business support/marketing support activities by Aramco Asia India Private Limited would create a Permanent Establishment for Saudi Arabian Oil Company in India under Article 5 of India-Saudi Arabia DTAA --- Held No; Whether the advance ruling application under section 245Q(1) is maintainable for proposed transactions --- Held Yes

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