IN RE: ABC INTERNATIONAL INC. USA Vs. STATE

JUDGEMENT

(1.) THE applicant has approached this Authority being desirous of obtaining an advance ruling on a transaction which is proposed to be undertaken. The nature of the activity as set out by the applicant in its application is as follows: -

(2.) IN case the above income is held to be taxable in India considering the provisions of the Act or DTAA, what will be the amount taxable in India and whether such income will be taxed at the time of discounting of the bills of exchange or promissory notes or on their maturity or on rediscounting thereof?

(3.) WHETHER the income of the applicant will still be subject to withholding tax under section 195 of the Act in case the income from above transaction is held to be 'not taxable' in India.