https://www.taxtmi.com/caselaws?id=350573 Freight earned from feeder vessels used under slot hire arrangements was treated as profits from the operation of ships in international traffic and therefore qualified for Article 8 relief under the India-Germany DTAA, even though the vessels were neither owned nor chartered by the assessee. The Tribunal followed its earlier view in the assessee's own cases and the Bombay High Court's ruling in Balaji Shipping. It also applied the principle that interest under section 234B is not leviable on a non-resident where tax was deductible at source, and held the interest levy unsustainable. en-us Tue, 31 Oct 2017 00:00:00 +0530 Fri, 04 Feb 2022 12:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350573 Freight earned from feeder vessels used under slot hire arrangements was treated as profits from the operation of ships in international traffic and therefore qualified for Article 8 relief under the India-Germany DTAA, even though the vessels were neither owned nor chartered by the assessee. The Tribunal followed its earlier view in the assessee's own cases and the Bombay High Court's ruling in Balaji Shipping. It also applied the principle that interest under section 234B is not leviable on a non-resident where tax was deductible at source, and held the interest levy unsustainable. Case-Laws Income Tax Tue, 31 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350573