https://www.taxtmi.com/caselaws?id=122229 Inland haulage charges under a composite shipping arrangement were treated as income directly connected with the operation of ships in international traffic under Article 8 of the Indo-Belgium DTAA, so they were not taxable in India. Interest on income-tax refund was treated as interest income under Article 11, because the refund amount did not have the required direct nexus with ship operations for Article 8(2)(a); it was therefore taxable, but only at the treaty rate of 15 per cent of the gross amount. The interpretation emphasised that an inland leg integrated into international carriage may fall within shipping profits, while refund interest remains separate unless the underlying funds are directly tied to the shipping business. en-us Fri, 21 May 2010 00:00:00 +0530 Thu, 09 Aug 2012 15:33:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122229 Inland haulage charges under a composite shipping arrangement were treated as income directly connected with the operation of ships in international traffic under Article 8 of the Indo-Belgium DTAA, so they were not taxable in India. Interest on income-tax refund was treated as interest income under Article 11, because the refund amount did not have the required direct nexus with ship operations for Article 8(2)(a); it was therefore taxable, but only at the treaty rate of 15 per cent of the gross amount. The interpretation emphasised that an inland leg integrated into international carriage may fall within shipping profits, while refund interest remains separate unless the underlying funds are directly tied to the shipping business. Case-Laws Income Tax Fri, 21 May 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122229