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    <title>2013 (11) TMI 1325 - ITAT MUMBAI</title>
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    <description>Article 8 of the India-Singapore DTAA was interpreted to cover profits from ships in international traffic and activities directly connected with such transport, including slot charter and feeder vessel operations where the cargo movement was factually linked to the relevant hubs and onward carriage. Treaty protection was held available for voyages supported by evidence, subject to verification by the Assessing Officer. For voyages lacking supporting documents, treaty benefit was declined on the existing material and domestic taxation under section 44B of the Income-tax Act was directed to apply to those unsupported voyages.</description>
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