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    <title>2015 (12) TMI 401 - GUJARAT HIGH COURT</title>
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    <description>Transport of goods by vessel between two Indian ports was treated as &quot;international traffic&quot; under the India-Singapore Double Taxation Avoidance Agreement because the treaty exclusion applies only where the ship is operated solely between places in the other Contracting State. As the vessels formed part of a larger voyage from Singapore to Dubai and were not confined solely to movement between the Indian ports, the exclusion did not apply. The assessee was therefore entitled to Article 8 relief, and the Revenue&#039;s appeals were dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=269097</link>
      <description>Transport of goods by vessel between two Indian ports was treated as &quot;international traffic&quot; under the India-Singapore Double Taxation Avoidance Agreement because the treaty exclusion applies only where the ship is operated solely between places in the other Contracting State. As the vessels formed part of a larger voyage from Singapore to Dubai and were not confined solely to movement between the Indian ports, the exclusion did not apply. The assessee was therefore entitled to Article 8 relief, and the Revenue&#039;s appeals were dismissed.</description>
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