1995 (12) TMI 396

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....ivate limited company incorporated in the United Kingdom, the affairs of which are managed in the United Kingdom so that it is a non-resident company for the purposes of the Act. The transactions which the company proposes to enter into and with regard to which an advance ruling from this Authority is sought are set out thus in the application : "We are in the process of acquiring a number of r....

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....s are eligible to be treated in the same category as export of Indian goods which earn foreign exchange. The specific relief we desire is with regard to income-tax exemption on such earnings." This Authority addressed a letter to the applicant calling upon it to specify the precise provisions of the statute under which rupee earning could be treated as invisible export as also the exact relief in....

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....y some specific provision exempting them from tax. The applicant seems to suggest that its earnings should be treated as in the nature of invisible exports by reason of savings in foreign exchange. This assumption is not correct and unless the details of the letting are clearly known, it is not possible to postulate that the rents received from the Indian companies in rupees would necessarily be l....

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....tion, we are unable to accept the plea of the applicant that it should be entitled to some sort of exemption, whole or partial, in respect of the transactions proposed. The question for the ruling of this Authority has been framed somewhat cumbrously in the annexure to the application. It reads : "We would like to collect the rent for these apartments in the U. K. on an ongoing basis from India....