Form of application for obtaining an advance ruling section 383(1) of the Act

1.

Name

(Refer note 1)

2.

Permanent Account Number (PAN), if any

(Refer note 2)

3.

Status

(Refer note 3)

4.

If reply to row 3 is Individual and no Permanent Account Number is provided in row 2, then provide following:

(i)

Gender

(ii)

Name of Father/Husband*

(Refer note 1)

(iii)

Date ofBirth

dd/mm/yyyy

5.

Address

(Refer note 4)

6.

Contact Details

Mobile Number

Country Code

Number

Email ID

7.

Country of Residence or Citizenship

8.

Date of Incorporation

dd/mm/yyyy

9.

Details of Authorized Representative in India:

(i)

Name

(Refer note 1)

(ii)

Address

(Refer note 4)

10.

If no Permanent Account Number is provided in row 2, then provide the details of Jurisdictional Assessing Officer.

11.

(i)

Business of the applicant as per Memorandum of Association or Partnership Deed or Trust Deed etc.

(ii)

Attach copy of Memorandum of Association or Partnership Deed or Trust Deed etc. referred in row 11(i).

(Upload)

Part B: Purpose of application

12.

Residential Status

(Select One)

(i) Resident

(ii) Non- Resident

13.

DTAA involved (wherever applicable)

14.

(i)

If the answer to row 12 is Non-Resident, then provide basis of claim for being a non-resident

(Free Text up to 200

words)

(ii)

Attach proof of being non-resident as mentioned in row 14(i)

(Upload)

15.

Determination of advance ruling in relation to

(Select One)

(Refer note 5)

16.

(i)

Question(s) relating to the transaction on which the advance ruling is required

(Upload)

(ii)

Brief Summary of question(s) asked

(Free Text upto 200

words)

(iii)

Relevant sections of the Act

(Free Text upto 200

words)

Part C: Specific Details and Annexures/Documents

17.

Statement of the relevant facts having a bearing on the question(s) referred to in row 16.

(Upload)

(Refer note 6)

18.

Statement containing the applicant‘s interpretation of law or facts, as the case may be, in respect of the question(s) referred in row 16.

(Upload)

(Refer note 6)

19.

Details of Relevant Agreements

(a)

Description of Relevant Agreement, if any

(b)

Copy of Relevant Agreement

(Upload)

(c)

Period Covered by the Agreement(s) (if any)

Year (From)

Year (To)

(Repeat as required)

20.

Fee payment details along with proof of payment

(A)

(i)

Amount ofFee paid

(ii)

Bank Details

(iii)

Date of Challan

(iv)

Challan No.

(B)

(Repeat as required)

21.

(a)

Total No. of Non-Resident Parties involved including the Applicant

(b)

Group Structure Details of Non-Resident Applicant and Non- Resident parties involved

(Upload)

(Refer note 7)

(c)

(i)

Name of Non-Resident applicant or party involved

(Refer note 1)

(ii)

Permanent Account Number, if any

(iii)

Status

(Refer note 3)

(iv)

Taxpayer Identification Number (TIN)

(v)

Address

(Refer note 4)

(vi)

Country of Residence

(vii)

Shareholding Details (Percentage wise)

(d)

(i)

Name of Immediate Parent Company/Holding Entity

(ii)

(repeat (ii) to (vii) as above)

(e)

(i)

Name of Ultimate Parent Company/ Holding Entity

(ii)

Repeat (ii) to (vii) of row 21(c), as above

(f)

(i)

Name of Beneficial Owner(s) of the Ultimate Parent Company or Holding Entity

(Refer note 8)

(ii)

Repeat (ii) to (vii) of row 21(c), as above

(Repeat, if required)

22.

Amount of Transaction along with Tax Year(s)

(A)

(i)

Tax Year(s)

(ii)

Amount of Transaction

(B)

(Repeat as required)

23.

(A)

Same or Similar Issues decided by any Income Tax Authority or Tribunal or Court in the case of the applicant.

(Select One)

(i) Yes

(ii) No

If the answer to row 23(A) is Yes, then provide the following:

(B)

(i)

Issue

Free Text upto 200

words

(ii)

Tax Year

(iii)

Income Tax Authority or Tribunal or Court

(iv)

Summary or Conclusion thereof

Free Text upto 200

words

(C)

(Repeat if required)

24.

(A)

Whether Proceedings (if any) pertaining to the Applicant or any other entity of Applicant's Group Pending Before the BAR on same or similar transaction(s)

(Select One)

(i) Yes

(ii) No

If reply to row 24(A) is yes, then provide the following details:

(B)

(a)

Entity Name

(b)

Address

(Refer note 4)

(c)

Permanent Account Number

(d)

Application Details in BAR

(i)

BAR

(Select One)

(i)BAR I

(ii)BAR II

(iii)BAR III

(ii)

Application Number

(iii)

Date of Filing

dd/mm/yyyy

(iv)

Date of admission

dd/mm/yyyy

(v)

Current status

Free text upto 200

words

(vi)

Brief Summary of issue(s) and question(s) asked

Free text upto 200

words

(Repeat as required)

25.

Do you agree to the publication of the ruling/order in an anonymized form?

(Select One)

(i) Yes

(ii) No

26.

If reply to row 15 is an arrangement, as referred to in Chapter XI, then provide details of Specified Impermissible Arrangement (GAAR) for Application

(A)

Details of the arrangement to be undertaken by the applicant on which a determination or decision of the Board is required

(i)

Brief description of the arrangement

(ii)

Purpose or purposes of the arrangement

(iii)

Details of the other parties to the arrangement in the following format:

(a)

Name of the other party (ies) to the arrangement

(b)

Whether resident in India

(Select One)

(i)Yes

(ii) No

(c)

Permanent Account Number

(d)

Role of such party in arrangement

Free text upto 200

words

(e)

Relationship with other party(ies) to the arrangement

Free text upto 200

words

(f)

Tax benefit arising to the other party(ies), if any

Free text upto 200

words

(Repeat (a) to (f), if required)

(B)

The tax benefit which is likely to arise out of arrangement, if undertaken

Free text upto 200

words

(C)

Tax year, or years during which the tax benefit as indicated as above is likely to arise (give year wise break-up)

(Upload)

27.

If reply to row 15 is relating to computation of total income of a notified resident applicant which is pending before any income-tax authority or the Appellate Tribunal, then provide details relating to appeal

(A)

Details of Assessment

(i)

Tax Year

(ii)

Date of Assessment Order

dd/mm/yyyy

(iii)

section under which the original order was Passed

(iv)

Assessing Officer

(v)

Whether Assessment Order or Current status of Proceedings is enclosed in row 17 or 18.

(Select One)

(i) Yes

(ii) No

(Repeat as required)

(B)

Details of Appeal

(i)

Appeal No.

(ii)

Date of Appeal before the Commissioner of Income- tax (Appeals) or the Tribunal

dd/mm/yyyy

(iii)

Whether Grounds of Appeal and Current Status of Appeal or Relevant Appellate Order(s) are enclosed in row 17 or 18.

(Select One)

(i) Yes

(ii) No

(Repeat as required)

Place:

Date:

(Signature)

Name:

Designation:

Verification

I, [name in full and in block letters] *son/daughter/spouse of having PAN of [name of the entity] do hereby solemnly declare that to the best of my knowledge and belief what is stated above and, in the annexure, (s), including the documents accompanying such annexure(s), is correct and complete. I further declare that I am making this application in my capacity as (Designation) and that I am competent to make this application and verify it.

I also declare that the question(s) on which the advance ruling is sought is/are* not pending/pending* in my case before any income-tax authority, the Appellate Tribunal or any court.

Verified today, the...............................day of..........................

*Delete whichever is not applicable.

Place:

Date:

Signature

(Name: ___________)

Designation: