https://www.taxtmi.com/caselaws?id=330146 Section 44B could not be applied to a Singapore-resident non-vessel operating common carrier that did not own, charter or lease vessels, because the shipping-business deeming provision was not triggered merely by participation in the shipping line business model. The Revenue also failed to establish a Permanent Establishment in India or effective control and management in India on the material before the Tribunal. In the absence of a PE, business profits were not chargeable in India under Article 7 of the India-Singapore DTAA, and the income was held not taxable in India. en-us Fri, 15 Jul 2016 00:00:00 +0530 Tue, 19 Jul 2016 13:03:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330146 Section 44B could not be applied to a Singapore-resident non-vessel operating common carrier that did not own, charter or lease vessels, because the shipping-business deeming provision was not triggered merely by participation in the shipping line business model. The Revenue also failed to establish a Permanent Establishment in India or effective control and management in India on the material before the Tribunal. In the absence of a PE, business profits were not chargeable in India under Article 7 of the India-Singapore DTAA, and the income was held not taxable in India. Case-Laws Income Tax Fri, 15 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330146