Appeals from the Authority of Advance Rulings The Implications of Columbia Sportswear v. DTT, Bangalore

Abstract

The Authority for Advance Rulings [hereinafter referred to as "the Authority" or the "AAR"] in India was set up under Chapter XIX-B of the Income Tax Act, 1961 by the Finance Act of 1993 keeping in mind that owing to the complexity of modern tax laws, international taxpayers need certainty with respect to the tax implications of transactions they propose to undertake before making investments in a foreign country. An Authority for Advance Rulings (Income Tax) under Section 245N of the Income Tact Act, 1961 has been set up to provide advance rulings to applicants seeking determination of the tax liability of a non-resident or a resident applicant with such non-resident in relation to a transaction which has been undertaken or is proposed to be undertaken by such applicants. The rulings of the AAR are only binding on the parties applying for the same.