https://www.taxtmi.com/caselaws?id=339293 Whether amounts received for use of a global telecommunication system constituted "fees for technical services" under the Indo-Danish DTAA or formed part of shipping business profits. The SC held that, once the Revenue accepted treaty protection for freight income as profits from operation of ships, the telecommunication system was an integral, indispensable facility for conducting the shipping business and was merely shared with agents to enable performance of agency functions. Applying the principle that mere use of a common facility is not "technical services" requiring specialised services, the receipts were treated as part of shipping business income and not taxable as fees for technical services; the HC view was affirmed. en-us Fri, 17 Feb 2017 00:00:00 +0530 Mon, 05 Jan 2026 16:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339293 Whether amounts received for use of a global telecommunication system constituted "fees for technical services" under the Indo-Danish DTAA or formed part of shipping business profits. The SC held that, once the Revenue accepted treaty protection for freight income as profits from operation of ships, the telecommunication system was an integral, indispensable facility for conducting the shipping business and was merely shared with agents to enable performance of agency functions. Applying the principle that mere use of a common facility is not "technical services" requiring specialised services, the receipts were treated as part of shipping business income and not taxable as fees for technical services; the HC view was affirmed. Case-Laws Income Tax Fri, 17 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339293