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 contended by the Applicant Funds. (a) Facts. The Applicants (i.e. all the funds) were registered either in Canada or the US. It was set up to provide investors with continuous income from managed investment in securities...