https://www.taxtmi.com/caselaws?id=343481 Shipping profits not specifically allocated by earlier treaty articles were treated as falling within the residuary article, so they were taxable only in the State of residence and not under domestic Indian law. The Indian agency was nevertheless found to be a dependent and economically connected agent, and therefore a permanent establishment. Even so, the ships generating the income were not economically owned by, or effectively connected with, that permanent establishment, so the treaty taxing right did not shift to India. The revenue appeal and cross objection were dismissed on that basis. en-us Thu, 25 May 2017 00:00:00 +0530 Fri, 26 May 2017 07:11:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343481 Shipping profits not specifically allocated by earlier treaty articles were treated as falling within the residuary article, so they were taxable only in the State of residence and not under domestic Indian law. The Indian agency was nevertheless found to be a dependent and economically connected agent, and therefore a permanent establishment. Even so, the ships generating the income were not economically owned by, or effectively connected with, that permanent establishment, so the treaty taxing right did not shift to India. The revenue appeal and cross objection were dismissed on that basis. Case-Laws Income Tax Thu, 25 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343481