https://www.taxtmi.com/caselaws?id=122133 Treaty relief under Article 9 of the India-France DTAA for shipping income depended on proof of the factual nexus between feeder vessels and mother vessels, including evidence of ownership, lease or charter arrangements; because the record was incomplete, the matter was remitted for fresh verification. Inland haulage charges were treated as consequential to that principal Article 9 issue and were also sent back for reconsideration. The assessee's alternative grounds on absence of a permanent establishment and the applicable tax rate likewise required fresh adjudication if any income remained taxable after the treaty claim was reassessed. en-us Fri, 23 Jul 2010 00:00:00 +0530 Wed, 08 Aug 2012 17:46:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122133 Treaty relief under Article 9 of the India-France DTAA for shipping income depended on proof of the factual nexus between feeder vessels and mother vessels, including evidence of ownership, lease or charter arrangements; because the record was incomplete, the matter was remitted for fresh verification. Inland haulage charges were treated as consequential to that principal Article 9 issue and were also sent back for reconsideration. The assessee's alternative grounds on absence of a permanent establishment and the applicable tax rate likewise required fresh adjudication if any income remained taxable after the treaty claim was reassessed. Case-Laws Income Tax Fri, 23 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122133