https://www.taxtmi.com/caselaws?id=249650 Freight income from carriage of cargo through feeder vessels under slot or space charter arrangements was treated as part of the "operation of ships" for Article 8 of the India-Malaysia DTAA, because the charterer concept was read broadly and the feeder movement was commercially inseparable from the onward voyage. Interest under section 234B was held not leviable where the income was subject to tax deduction at source and binding precedent applied. Interest under section 234D was held not chargeable where the original assessment had already been completed under section 143(3) and later reassessment could not be treated as a regular assessment. Interest income was also stated to be taxable at the beneficial treaty rate under Article 11. en-us Wed, 16 Jul 2014 00:00:00 +0530 Sat, 19 Jul 2014 09:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249650 Freight income from carriage of cargo through feeder vessels under slot or space charter arrangements was treated as part of the "operation of ships" for Article 8 of the India-Malaysia DTAA, because the charterer concept was read broadly and the feeder movement was commercially inseparable from the onward voyage. Interest under section 234B was held not leviable where the income was subject to tax deduction at source and binding precedent applied. Interest under section 234D was held not chargeable where the original assessment had already been completed under section 143(3) and later reassessment could not be treated as a regular assessment. Interest income was also stated to be taxable at the beneficial treaty rate under Article 11. Case-Laws Income Tax Wed, 16 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249650