https://www.taxtmi.com/caselaws?id=249259 Shipping income and feeder freight were treated as belonging to the two Danish ship-owning companies, because the assessee acted only as managing owner and representative and was not the beneficial owner of the vessels, bills of lading or freight receipts. The freight could not be assessed in the assessee's hands merely because returns were filed in a representative capacity. Management fees paid by one non-resident to another were also held outside Indian tax on the facts, as Article 13(6) of the India-Denmark DTAA was not satisfied in the absence of the required connection with a permanent establishment or fixed base in India. en-us Wed, 18 Jun 2014 00:00:00 +0530 Tue, 17 Mar 2015 16:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249259 Shipping income and feeder freight were treated as belonging to the two Danish ship-owning companies, because the assessee acted only as managing owner and representative and was not the beneficial owner of the vessels, bills of lading or freight receipts. The freight could not be assessed in the assessee's hands merely because returns were filed in a representative capacity. Management fees paid by one non-resident to another were also held outside Indian tax on the facts, as Article 13(6) of the India-Denmark DTAA was not satisfied in the absence of the required connection with a permanent establishment or fixed base in India. Case-Laws Income Tax Wed, 18 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249259