https://www.taxtmi.com/caselaws?id=236581 Receipts integrally connected with international shipping operations, including freight from four vessels and cargo tracking facilities, were treated as covered by Article 9 of the India-Denmark treaty and section 44B rather than as separately taxable income in India. The freight receipts had a direct nexus with the composite shipping business and were not taxed on a gross-estimate basis. The cargo tracking receipts were found to be cost reimbursement or part of the shipping business, not fees for technical services, and were therefore not taxable in India. As the assessee had no advance tax liability on the income in question, interest under section 234B was also not leviable. en-us Wed, 28 Aug 2013 00:00:00 +0530 Mon, 02 Sep 2013 09:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236581 Receipts integrally connected with international shipping operations, including freight from four vessels and cargo tracking facilities, were treated as covered by Article 9 of the India-Denmark treaty and section 44B rather than as separately taxable income in India. The freight receipts had a direct nexus with the composite shipping business and were not taxed on a gross-estimate basis. The cargo tracking receipts were found to be cost reimbursement or part of the shipping business, not fees for technical services, and were therefore not taxable in India. As the assessee had no advance tax liability on the income in question, interest under section 234B was also not leviable. Case-Laws Income Tax Wed, 28 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236581