https://www.taxtmi.com/caselaws?id=239793 Freight income from international shipping was held taxable in the hands of the two Danish companies, not the managing Indian firm, because the vessels, bills of lading and operations belonged to the companies. Treaty protection under the India-Denmark DTAA was available since the partnership income was fully taxed in Denmark through the partners, despite fiscal transparency. Management fees paid by the Danish companies were not chargeable in India absent the treaty conditions for source taxation, and reimbursements for global IT and software costs were treated as cost-sharing without independent technical or royalty character. Interest under section 234B was not leviable, while the section 234D issue required reconsideration in line with the Supreme Court ruling. en-us Fri, 08 Nov 2013 00:00:00 +0530 Fri, 22 Nov 2013 08:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239793 Freight income from international shipping was held taxable in the hands of the two Danish companies, not the managing Indian firm, because the vessels, bills of lading and operations belonged to the companies. Treaty protection under the India-Denmark DTAA was available since the partnership income was fully taxed in Denmark through the partners, despite fiscal transparency. Management fees paid by the Danish companies were not chargeable in India absent the treaty conditions for source taxation, and reimbursements for global IT and software costs were treated as cost-sharing without independent technical or royalty character. Interest under section 234B was not leviable, while the section 234D issue required reconsideration in line with the Supreme Court ruling. Case-Laws Income Tax Fri, 08 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239793