https://www.taxtmi.com/caselaws?id=328044 Profits from slot hire and other directly connected shipping activities in international traffic were treated as covered by Article 8 of the India-Indonesia tax treaty, which allocated exclusive taxing rights to the residence State. The activity was regarded as part of the business of carriage of goods by sea, so treaty protection extended beyond carriage by an owner or charterer. Section 172 of the Income-tax Act could not be invoked to deny treaty relief unless the assessee was shown to be the owner or charterer of the vessel. On that basis, source taxation under section 172 was unsustainable and the assessment additions and demand were vacated. en-us Mon, 18 Apr 2016 00:00:00 +0530 Wed, 25 May 2016 08:25:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328044 Profits from slot hire and other directly connected shipping activities in international traffic were treated as covered by Article 8 of the India-Indonesia tax treaty, which allocated exclusive taxing rights to the residence State. The activity was regarded as part of the business of carriage of goods by sea, so treaty protection extended beyond carriage by an owner or charterer. Section 172 of the Income-tax Act could not be invoked to deny treaty relief unless the assessee was shown to be the owner or charterer of the vessel. On that basis, source taxation under section 172 was unsustainable and the assessment additions and demand were vacated. Case-Laws Income Tax Mon, 18 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328044