The Indian tax authority has filed a "Special Leave Petition" (SLP) with the Supreme Court of India, seeking to challenge the advance ruling dated 13 February 2006 in the case of Morgan Stanley and Co. v. Director of Income-tax (International Taxation) (284 ITR 260). In the advance ruling, the Indian Authority for Advance Rulings (AAR) held that Morgan Stanley and Co's (henceforth "Morgan Stanley") captive business process outsourcing (BPO) in India was not its permanent establishment (PE) under Art. 5 of the India-US (the tax treaty). Hence, the income would not be taxable in India. The Supreme Court has issued...