Session I Enhanced role of AAR going forward including specific issues relating to domestic transactions that can be pursued before the AAR

1.With the increased cross border transactions, growing international business of Indian MNCs and many MNCs operating in India, do you think AAR is a proper Forum for speedy justice? Do you think with starting of additional 2 benches, if the ruling is available within 6 months, will AAR be a proper Forum for speedy justice? Page No 3

2. Do you think the threshold limit of Rs.100 crores for being eligible to file the applications for domestic transactions and hefty filing fees will be deterrent for filing of applications by many people? Page No 4

3. Do you think that with the ruling available from AAR in respect of domestic transactions overall litigation on importance principles will go down? Page No 5

4. After GAAR becomes applicable, will it be correct to consider AAR as a proper forum for getting ruling about the non-avoidance of tax? Page No 6

5.What type of domestic transactions do you think can be taken up before the AAR? Page No 7

6.What is the meaning of “transaction proposed to be undertaken”? Would it include a transaction intended to be carried out? Page No 8

7.With an increase in the number of benches, is there likely to be an increase in the inconsistency of rulings? What do you think should be the measures taken to reduce such inconsistency? Page No 9

8.Whether issues arising Domestic Transfer pricing can be takefrom n before the AAR? Page No 10

9.Since the ruling given by AAR is binding only for the applicant, can that be said to have precedent value or persuasive value either for other matters before AAR or before any other Tax Authorities? Page No 11

Questions?