CUSHMAN AND WAKEFIELD (S) PTE. LTD. Vs. DIT (INTERNATIONAL TAXATION)

JUDGEMENT

(1.) THE application under Section 245Q(1) of the Income -tax Act, 1961 (in short the Act) has been filed by M/s Cushman & Wakefield(S) Pte.Ltd., Singapore (in short, CWS), seeking advance ruling from the Authority on the questions mentioned therein.

(2.) FACTS :

(3.) WHILE commenting on the admissibility of the application, the Director of Income -tax (International Taxation) New Delhi has submitted that for want of sufficient and material facts, they are not in a position to take any stand on the characterization of income received by the applicant and the consequential tax liability thereof.