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The ITAT upheld that inland haulage charges (IHC) earned by the assessee are integrally connected to the operation of ships in international traffic and thus qualify for the benefits under Article 8 of the India-UAE DTAA. The Tribunal relied on prior precedents establishing that IHC forms part of the shipping business profits and cannot be separately taxed as business income in India. Consequently, the Assessing Officer's denial of treaty benefits and assessment of inland haulage and shipping receipts at 3.5% was set aside. The appeal was allowed, affirming that such income is exempt from Indian taxation under the DTAA provisions governing income from the operation of ships in international traffic.
The ITAT upheld that inland haulage charges (IHC) earned by the assessee are integrally connected to the operation of ships in international traffic and thus qualify for the benefits under Article 8 of the India-UAE DTAA. The Tribunal relied on prior precedents establishing that IHC forms part of the shipping business profits and cannot be separately taxed as business income in India. Consequently, the Assessing Officer's denial of treaty benefits and assessment of inland haulage and shipping receipts at 3.5% was set aside. The appeal was allowed, affirming that such income is exempt from Indian taxation under the DTAA provisions governing income from the operation of ships in international traffic.
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