https://www.taxtmi.com/caselaws?id=257157 Shipping profits from the operation of ships in international traffic were treated as falling under the residuary treaty article for income not otherwise dealt with, so section 44B could not override the more beneficial India-Switzerland treaty rule. A permanent establishment in India was recognised on the agency facts, but the ships were not shown to be effectively connected with that establishment, so Article 7 did not apply. Interest on income-tax refund was classified as interest income under the treaty's interest article, not as business profits. Interest under section 234B was held not leviable where tax was deductible at source and treaty protection applied. en-us Fri, 20 Feb 2015 00:00:00 +0530 Fri, 15 May 2015 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257157 Shipping profits from the operation of ships in international traffic were treated as falling under the residuary treaty article for income not otherwise dealt with, so section 44B could not override the more beneficial India-Switzerland treaty rule. A permanent establishment in India was recognised on the agency facts, but the ships were not shown to be effectively connected with that establishment, so Article 7 did not apply. Interest on income-tax refund was classified as interest income under the treaty's interest article, not as business profits. Interest under section 234B was held not leviable where tax was deductible at source and treaty protection applied. Case-Laws Income Tax Fri, 20 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257157