https://www.taxtmi.com/caselaws?id=203313 Interest on income-tax refund received by a non-resident shipping company was held taxable under Article 11 of the India-Germany DTAA, because it constituted interest on a debt-claim and not profits from the operation of ships in international traffic. Article 8(3) was confined to interest on funds directly connected with ship or aircraft operations and did not extend to interest arising from a statutory tax refund. The tax refund and the shipping business were distinct, so the interest could not take the character of shipping profits. Article 11 therefore prevailed, and exemption under Article 8(3) was denied. en-us Mon, 27 Dec 2010 00:00:00 +0530 Mon, 05 Sep 2011 18:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203313 Interest on income-tax refund received by a non-resident shipping company was held taxable under Article 11 of the India-Germany DTAA, because it constituted interest on a debt-claim and not profits from the operation of ships in international traffic. Article 8(3) was confined to interest on funds directly connected with ship or aircraft operations and did not extend to interest arising from a statutory tax refund. The tax refund and the shipping business were distinct, so the interest could not take the character of shipping profits. Article 11 therefore prevailed, and exemption under Article 8(3) was denied. Case-Laws Income Tax Mon, 27 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203313