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    <title>1996 (3) TMI 174 - ITAT DELHI-B</title>
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    <description>A drilling vessel was treated as a ship because it was self-propelled, navigable, registered as a ship and retained the character of a sea-going vessel despite offshore drilling use, so the exemption under section 10(6)(viii) was available. Salary attributable to the field break period received outside India was held not to accrue or arise in India under section 9(1)(ii), and was therefore not taxable in India. Treaty relief under Article XIV of the India-France DTAA was denied because the exemption depended on cumulative conditions and the record did not establish that each condition was satisfied.</description>
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    <pubDate>Tue, 26 Mar 1996 00:00:00 +0530</pubDate>
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      <title>1996 (3) TMI 174 - ITAT DELHI-B</title>
      <link>https://www.taxtmi.com/caselaws?id=63465</link>
      <description>A drilling vessel was treated as a ship because it was self-propelled, navigable, registered as a ship and retained the character of a sea-going vessel despite offshore drilling use, so the exemption under section 10(6)(viii) was available. Salary attributable to the field break period received outside India was held not to accrue or arise in India under section 9(1)(ii), and was therefore not taxable in India. Treaty relief under Article XIV of the India-France DTAA was denied because the exemption depended on cumulative conditions and the record did not establish that each condition was satisfied.</description>
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      <pubDate>Tue, 26 Mar 1996 00:00:00 +0530</pubDate>
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