https://www.taxtmi.com/caselaws?id=257212 Shipping profits under the Indo-Swiss treaty were treated as income not specifically dealt with in the earlier distributive articles and therefore fell within the residuary article, allocating taxing rights to the State of residence. The Indian shipping agent was found to be a permanent establishment because it worked exclusively and dependently for the non-resident shipowner, but the ships themselves were not economically owned by or allocated to that establishment. On that basis, the income was not attributable to a right or property effectively connected with the permanent establishment, so the treaty benefit remained available and Indian domestic taxation did not apply. en-us Wed, 17 Dec 2014 00:00:00 +0530 Wed, 04 Mar 2015 13:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257212 Shipping profits under the Indo-Swiss treaty were treated as income not specifically dealt with in the earlier distributive articles and therefore fell within the residuary article, allocating taxing rights to the State of residence. The Indian shipping agent was found to be a permanent establishment because it worked exclusively and dependently for the non-resident shipowner, but the ships themselves were not economically owned by or allocated to that establishment. On that basis, the income was not attributable to a right or property effectively connected with the permanent establishment, so the treaty benefit remained available and Indian domestic taxation did not apply. Case-Laws Income Tax Wed, 17 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257212