https://www.taxtmi.com/caselaws?id=216002 Income from slot chartering used in sea transport can fall within the shipping article of an India-UK tax treaty when the activity is directly connected with, or ancillary to, the taxpayer's international shipping operations. The Bombay HC treated slot hire as part of the shipping business where ships, containers and slot facilities were used together for carriage to overseas destinations, and therefore regarded the receipts as covered by Article 9 and exempt in the State of residence. It also treated section 44B as supporting the same commercial context, but not as displacing treaty relief. en-us Mon, 06 Aug 2012 00:00:00 +0530 Mon, 20 Feb 2017 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216002 Income from slot chartering used in sea transport can fall within the shipping article of an India-UK tax treaty when the activity is directly connected with, or ancillary to, the taxpayer's international shipping operations. The Bombay HC treated slot hire as part of the shipping business where ships, containers and slot facilities were used together for carriage to overseas destinations, and therefore regarded the receipts as covered by Article 9 and exempt in the State of residence. It also treated section 44B as supporting the same commercial context, but not as displacing treaty relief. Case-Laws Income Tax Mon, 06 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216002