Loss of hand wirtten notes and book on ABC of International tax

[Anagha Narkar]

Hi All,

 

I have forgot the writting pad wherein I had noted down notes during the course on international taxation and a book named 'ABC of international taxation' in Jupiter hall. I had called up the hotel staff but they did not find it. Please let me know if someone has found it. Both, the book and a writting pad are unnamed.

 

Regards

 

Anagha Narkar

9881146851

[MADAN DESAI]

The notebook and ABC of IT is at branch

reg

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CA Madan M Desai
Chartered Accountants

[Anagha Narkar]

Thanks alot Mr. Desai.

 

Regards

 

Anagha

[Trilok N Thadani]

Dear All

 

Please provide your views:

 

One of my client has a holding Company located in the United States. The Holding Company has subscribed for debentures issued by the subsidiary Company located in India.

 

The subsidiary Company wants to pay the interest to the Holding Company.

 

Whether the provisions of Article 7 or Article 11 should be applied?

 

 

Regards

Trilok

[singhal...@gmail.com]

Hi Trilok,

In this case one must see whether subscription of debenture by holding is an investment activity or is it a business activity?

If the "business" of the holding is to make investment then income out of this will qualify as business income and thereby Art. 7 will come into picture.

If the subscription of debenture by holding is an investment activity then Art. 11 will apply. (One can see the accounting treatment of 'Sub.of Debenture' in the books of holding).

Hope this will give you some inputs. Others are also welcome for there Inputs/Comments.

Regards,
Amit Singhal

Sent from my BlackBerry® smartphone from !DEA

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From: "Trilok N Thadani" <thadan...@gmail.com>

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Date: Sun, 29 Apr 2012 15:03:18 +0530

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Subject: RE: [ICAI_Pune_Int-Tax] Loss of hand wirtten notes and book on ABC of International tax

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