https://www.taxtmi.com/caselaws?id=340873 Freight income from voyages operated by a Danish shipping enterprise was analysed under the India-Denmark treaty and section 172 of the Income-tax Act. The material discussed the charter arrangement, ownership, residency documents and control factors to determine that the Danish entity was the freight beneficiary and that its business was managed from Denmark, with the Jordan entity acting only as charterer. On that basis, the treaty rule on profits from ships in international traffic was applied so that taxability depended on the place of effective management, with the stated effect that the income was not chargeable in India. en-us Mon, 20 Mar 2017 00:00:00 +0530 Wed, 29 Mar 2017 07:08:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=340873 Freight income from voyages operated by a Danish shipping enterprise was analysed under the India-Denmark treaty and section 172 of the Income-tax Act. The material discussed the charter arrangement, ownership, residency documents and control factors to determine that the Danish entity was the freight beneficiary and that its business was managed from Denmark, with the Jordan entity acting only as charterer. On that basis, the treaty rule on profits from ships in international traffic was applied so that taxability depended on the place of effective management, with the stated effect that the income was not chargeable in India. Case-Laws Income Tax Mon, 20 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=340873