Indian ruling on classification of income of Canadian and US foreign institutional investors making portfolio investments in India

The India Authority for Advance Rulings (AAR) issued a ruling dated 8 January 2007 on applications filed by a number of funds managed by the Fidelity Group (i.e. 9 funds were registered in Canada and 31 funds registered in the United States (US)), holding that profits from sale of "portfolio investments" were taxable in India as "capital gains" and not as "business profits" as cont…
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