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ITAT allowed the Taxpayer's appeal, holding that Article 8 of the India-UAE DTAA governs the entire freight receipts from shipping operations, irrespective of whether earnings arise from feeder vessels or from ships in international traffic. The Tribunal concluded that inland haulage charges are inextricably linked to the operation of ships in international traffic and form an integral part of the profit from shipping business under Article 8. Consequently, such receipts fall within the DTAA allocation and are not taxable in India under section 44B of the IT Act. The Revenue's appeal was dismissed in respect of the shipping income and related inland haulage charges.
ITAT allowed the Taxpayer's appeal, holding that Article 8 of the India-UAE DTAA governs the entire freight receipts from shipping operations, irrespective of whether earnings arise from feeder vessels or from ships in international traffic. The Tribunal concluded that inland haulage charges are inextricably linked to the operation of ships in international traffic and form an integral part of the profit from shipping business under Article 8. Consequently, such receipts fall within the DTAA allocation and are not taxable in India under section 44B of the IT Act. The Revenue's appeal was dismissed in respect of the shipping income and related inland haulage charges.
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