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Section 245V of the Income-tax Act, 1961, read with rule 20 of the Authority for Advance Rulings (Procedure) Rules, 1996 - Records - Amendment of - Applicant, an Indian company, entered into an agreement with 'T Ltd.', Dubai and sought advance ruling on taxability of payment to be made to 'T Ltd.', Dubai - Applicant filed, instant application under rule 20 stating that registered office of 'T Ltd.' is at Mauritius and it is resident of Mauritius and sought amendment of application, filed for seeking advance ruling, by substituting 'T Ltd.' Dubai with 'T Ltd.' Mauritius - It also contended that 'T Ltd.', Dubai is only a branch of 'T Ltd.' Mauritius - Whether in absence of any material on record, it cannot be said that Dubai company is only a branch of Mauritius company - Held, yes - Whether, moreover, even if name of Mauritius company is permitted to be substituted in application, said company's tax liability cannot be determined as in agreement name of Dubai company is entered - Held, yes - Whether, therefore, application filed under rule 20 by applicant is liable to be dismissed - Held, yes FACTS The applicant, an Indian company, is engaged in the business management of sports events. It entered into an agreement with 'T Ltd.', Dubai. It sought advance ruling an taxability of payment to be made to 'T Ltd.', Dubai. During the course of hearing, the applicant filed instant application under rule 20 wherein it is stated that registered office of 'T Ltd.' is at Mauritius and it is resident of Mauritius and sought amendment of application, filed for seeking advance ruling, by substituting 'T Ltd.', Dubai, with 'T Ltd.' Mauritius. The applicant also contended that 'T Ltd.', Dubai is only a branch of 'T Ltd.' Mauritius. HELD A perusal of rule 20 shows that what is permitted to be amended by way of amendment of records is any factual or material error and such amendment can be made at any stage of proceedings before the Authority. [Para 5] From the facts it appears that 'T Ltd.' Dubai and 'T Ltd.' Mauritius are two different companies. In the absence of any material on record, it cannot be said that the Dubai company is only a branch of Mauritius company. In the…

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