https://www.taxtmi.com/caselaws?id=216485 Amounts recovered from Indian agents for access to a shared global communication and tracking system were treated as cost recovery under an integrated shipping facility, with no profit element and no service rendered in the nature of managerial, technical or consultancy services. The receipt was therefore not fees for technical services. The same receipt was also held to be directly connected with, and ancillary to, the operation of ships in international traffic, so it fell within the shipping profits article of the applicable DTAA and was not taxable in India. Additions made by the tax authorities were deleted. en-us Fri, 31 Aug 2012 00:00:00 +0530 Tue, 11 Sep 2012 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216485 Amounts recovered from Indian agents for access to a shared global communication and tracking system were treated as cost recovery under an integrated shipping facility, with no profit element and no service rendered in the nature of managerial, technical or consultancy services. The receipt was therefore not fees for technical services. The same receipt was also held to be directly connected with, and ancillary to, the operation of ships in international traffic, so it fell within the shipping profits article of the applicable DTAA and was not taxable in India. Additions made by the tax authorities were deleted. Case-Laws Income Tax Fri, 31 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216485