https://www.taxtmi.com/caselaws?id=151964 Entitlement to relief under the India-Japan shipping profits article was examined with section 90(2), which gives effect to the more beneficial treaty provision. The Tribunal treated the decisive conditions as whether the profits arose from the operation of ships in international traffic and whether the ships operated between India and Japan. A worldwide loss and the absence of tax payment in Japan were not treated as conditions for denying relief. On that basis, treaty relief at the prescribed rate was sustained and the Department's objection failed. en-us Wed, 18 Oct 2000 00:00:00 +0530 Thu, 20 Jun 2013 12:40:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151964 Entitlement to relief under the India-Japan shipping profits article was examined with section 90(2), which gives effect to the more beneficial treaty provision. The Tribunal treated the decisive conditions as whether the profits arose from the operation of ships in international traffic and whether the ships operated between India and Japan. A worldwide loss and the absence of tax payment in Japan were not treated as conditions for denying relief. On that basis, treaty relief at the prescribed rate was sustained and the Department's objection failed. Case-Laws Income Tax Wed, 18 Oct 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151964