Foreign company is liable for MAT u/s 115JB

CLR Editorial Notes: The applicant, a Mauritius company, sold shares of Burroughs Wellcome (India) Ltd. The resultant capital gains were not chargeable to tax under the India-Mauritius DTAA. The AAR had to consider whether, as the Applicant had no income chargeable to tax in India, (a) the transfer pricing provisions were applicable to its, (b) section 115JB (MAT) was… Read More

Tags: AAR, Companies Act, Dana Corporation, Double taxation, India, Mauritius, Supreme Court, Timken Company, transfer pricing, United States