https://www.taxtmi.com/caselaws?id=184965 Freight income from a ship operating in international traffic was treated as covered by Article 8 of the India-UK DTAA rather than taxed in India under section 172, because the vessel was owned and operated by a UK company, was chartered for the relevant voyage, and the freight belonged to the UK resident owner. The residency and ownership position was supported by the record, and the Department did not dislodge it with any adverse finding. The existence of a bank account in the United States did not defeat treaty protection. On these facts, the income qualified for treaty relief and was not taxable in India. en-us Fri, 12 Apr 2013 00:00:00 +0530 Tue, 26 Jul 2016 17:05:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184965 Freight income from a ship operating in international traffic was treated as covered by Article 8 of the India-UK DTAA rather than taxed in India under section 172, because the vessel was owned and operated by a UK company, was chartered for the relevant voyage, and the freight belonged to the UK resident owner. The residency and ownership position was supported by the record, and the Department did not dislodge it with any adverse finding. The existence of a bank account in the United States did not defeat treaty protection. On these facts, the income qualified for treaty relief and was not taxable in India. Case-Laws Income Tax Fri, 12 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184965