Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
The Appellate Tribunal considered the taxability of freight income u/s 44B for a foreign company incorporated in Singapore operating ships globally, including in India. The company argued that under Article 8 of the India-Singapore Treaty, shipping income should only be taxed in Singapore, its resident state. The Tribunal held that income from shipping in international traffic is taxable only in the resident state as per the treaty. The Tribunal rejected the application of Article 24 of the Treaty, as the company demonstrated its income was taxed in Singapore on accrual basis. Citing precedent, the Tribunal ruled in favor of the company, directing the deletion of additions to its Indian shipping income. The Appeals of the assesses were allowed.
The Appellate Tribunal considered the taxability of freight income u/s 44B for a foreign company incorporated in Singapore operating ships globally, including in India. The company argued that under Article 8 of the India-Singapore Treaty, shipping income should only be taxed in Singapore, its resident state. The Tribunal held that income from shipping in international traffic is taxable only in the resident state as per the treaty. The Tribunal rejected the application of Article 24 of the Treaty, as the company demonstrated its income was taxed in Singapore on accrual basis. Citing precedent, the Tribunal ruled in favor of the company, directing the deletion of additions to its Indian shipping income. The Appeals of the assesses were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
