https://www.taxtmi.com/caselaws?id=241331 Article 8 of the India-Cyprus DTAA specifically governs profits from the operation of ships in international traffic and allocates taxing rights to the Contracting State where the place of effective management is situated. For a foreign shipping enterprise with effective management in Cyprus, that treaty rule prevails over the Income-tax Act charging provisions and over the more general business-profits article. The practical effect is that shipping income of such an enterprise is not taxable in India under the treaty, and Indian tax authorities lack jurisdiction to levy tax on that income where the DTAA applies. en-us Mon, 18 Mar 2013 00:00:00 +0530 Sat, 21 Dec 2013 08:42:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241331 Article 8 of the India-Cyprus DTAA specifically governs profits from the operation of ships in international traffic and allocates taxing rights to the Contracting State where the place of effective management is situated. For a foreign shipping enterprise with effective management in Cyprus, that treaty rule prevails over the Income-tax Act charging provisions and over the more general business-profits article. The practical effect is that shipping income of such an enterprise is not taxable in India under the treaty, and Indian tax authorities lack jurisdiction to levy tax on that income where the DTAA applies. Case-Laws Income Tax Mon, 18 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241331