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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.
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