https://www.taxtmi.com/caselaws?id=122144 The Tribunal ruled that the non-resident company was not eligible for tax exemption under Article 8A of the DTAA between India and Netherlands as the hiring of containers was not considered incidental to the operation of ships. Regarding the existence of a Permanent Establishment (PE) in India, the matter was remanded to the Assessing Officer for further examination as all relevant Articles needed to be considered before a conclusion could be reached. The appeal by the revenue was allowed for statistical purposes, and the cross objection by the assessee was dismissed. en-us Fri, 02 Jul 2010 00:00:00 +0530 Wed, 08 Aug 2012 18:35:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122144 The Tribunal ruled that the non-resident company was not eligible for tax exemption under Article 8A of the DTAA between India and Netherlands as the hiring of containers was not considered incidental to the operation of ships. Regarding the existence of a Permanent Establishment (PE) in India, the matter was remanded to the Assessing Officer for further examination as all relevant Articles needed to be considered before a conclusion could be reached. The appeal by the revenue was allowed for statistical purposes, and the cross objection by the assessee was dismissed. Case-Laws Income Tax Fri, 02 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122144