1. Whether the amount reimbursed or reimbursable by the applicant to Target Corporation, USA, under the terms of the secondment agreement dated 10.6.2007 is in the nature of income accruing to Target in respect of which, tax is liable to be deducted at source by the applicant under the provisions of Income-tax Act, 1961?

The applicant undertakes work in Australia. It then sub-contracts a part of the work to its subsidiary, Infosys Australia. Infosys Australia performs the work wholly in Australia. The applicant makes payment to Infosys Australia for such work. The applicant wanted a ruling essentially on the question whether the payments made by it to Infosys Australia as consideration for the sub-contract work, is chargeable to tax in India, either under the Income-tax Act, 1961 or under the DTAA Convention between India and Australia.

whether the activities of affixation of different stickers, barcodes, assortment, debundling and bundling of different goods etc. can be regarded as “manufacture” within the meaning of S. 2(f) (ii) and (iii) of the Act.

transmission and wheeling charges paid by the applicant to the transmission company, RVPN is fees for technical services and the applicant has the obligation to withhold taxes under section 194J of the Act on such charges paid. I rule that SLDC Charges are not fees for technical services and no withholding of tax in terms of section 194J or 194C of the Act is called for on the said charge

Whether the payment under the Contract dated 7th August 2008 entered into between Grasim Industries Ltd. And HESS ACC System B.V. for supply of project services in relation to the Machinery sold by HESS to the purchaser are chargeable to tax under section 195 of Income-tax Act, 1961 or as per Article 12 para 5 read with para 6.(a) of the DTAA with the Netherlands?

1. Whether the Swiss Partnership/Partners would be treated as a resident of Switzerland under the terms of the Agreement for the Double Taxation and Prevention of Fiscal Evasion with the Swiss Confederation and hence be entitled to treaty benefits?