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    <title>2016 (1) TMI 791 - THE AUTHORITY FOR ADVANCE RULINGS NEW DELHI</title>
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    <description>The Authority ruled in favor of the Applicant on all issues, determining that the proposed transfer of shares would not be taxable in India under section 2(14) of the Act, capital gains would not be subject to tax due to the India-Mauritius DTAA, there was no Permanent Establishment in India, minimum alternate tax under section 115JB would not apply, transfer pricing provisions were inapplicable, no withholding tax was required under section 195, and the Applicant was not obligated to file a return of income under section 139 of the Act.</description>
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      <description>The Authority ruled in favor of the Applicant on all issues, determining that the proposed transfer of shares would not be taxable in India under section 2(14) of the Act, capital gains would not be subject to tax due to the India-Mauritius DTAA, there was no Permanent Establishment in India, minimum alternate tax under section 115JB would not apply, transfer pricing provisions were inapplicable, no withholding tax was required under section 195, and the Applicant was not obligated to file a return of income under section 139 of the Act.</description>
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