https://www.taxtmi.com/caselaws?id=121781 Profits from transporting cargo in international traffic through slot chartering or slot arrangement can fall within the treaty expression "operation of ships" even where the enterprise neither owns nor charters the vessels. The Tribunal applied the DTAA rule that such profits are taxable only in the State of residence and treated the treaty language as wide enough to cover these arrangements. Domestic shipping income provisions could not override the treaty benefit where the DTAA applied. The receipts from slot arrangement voyages were therefore entitled to treaty relief, and the Revenue's challenge failed. en-us Tue, 18 Nov 2008 00:00:00 +0530 Thu, 07 Dec 2023 19:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=121781 Profits from transporting cargo in international traffic through slot chartering or slot arrangement can fall within the treaty expression "operation of ships" even where the enterprise neither owns nor charters the vessels. The Tribunal applied the DTAA rule that such profits are taxable only in the State of residence and treated the treaty language as wide enough to cover these arrangements. Domestic shipping income provisions could not override the treaty benefit where the DTAA applied. The receipts from slot arrangement voyages were therefore entitled to treaty relief, and the Revenue's challenge failed. Case-Laws Income Tax Tue, 18 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=121781