TaxTMI 
TaxTMI 
2004 (4) TMI 5
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....r of Incomed-tax-I Chennai. Present for the Applicant Mr. V. Ramachandran, Sr. Advocate & others RULING (By Mr. Justice Syed Shah Mohammed Quadri) - In this case, the applicant filed application under section 245Q(1) of the Income-tax Act, 1961 seeking advance ruling on the following question: "Whether on the facts and circumstances of the case the remuneration received b....
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....To appreciate the ground of rejection stated in the aforementioned order, it would be useful to refer to the provisions of Section 245N of the Act defining the expression 'advance ruling' in so far as it is relevant for our purpose. Clasue (ii) of the definition is in the following terms: (a) "advance ruling" means - (i) x x x x • a determination by the Authority in relation to [the tax liabi....
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....hould relate to taxability of a non-resident arising out of a transaction which has been undertaken or is proposed to be undertaken by a resident applicant with such non-resident. Thus, it is evident that the advance ruling has to be in relation to the tax liability of a non-resident. Admittedly in this case the question in respect of which advance ruling is sought relates to the tax liability of ....