https://www.taxtmi.com/caselaws?id=203603 Amounts recovered as proportionate cost reimbursements for a global communication and shipping support facility were held not to be fees for technical services under the Income-tax Act or the DTAA, because they represented standard business support and not technical services rendered for a fee. The same receipts were also treated as directly connected with and ancillary to international shipping operations, so they fell within the treaty article for profits from operation of ships in international traffic. As the place of effective management was in Denmark, the DTAA allocated taxing rights there and excluded Indian taxation. The additions were deleted. en-us Fri, 11 Jun 2010 00:00:00 +0530 Wed, 08 Jun 2011 06:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203603 Amounts recovered as proportionate cost reimbursements for a global communication and shipping support facility were held not to be fees for technical services under the Income-tax Act or the DTAA, because they represented standard business support and not technical services rendered for a fee. The same receipts were also treated as directly connected with and ancillary to international shipping operations, so they fell within the treaty article for profits from operation of ships in international traffic. As the place of effective management was in Denmark, the DTAA allocated taxing rights there and excluded Indian taxation. The additions were deleted. Case-Laws Income Tax Fri, 11 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203603