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    <description>A 471-day delay in filing the appeal was explained by the assessee&#039;s foreign status, lack of office or employees in India, service at an old agent address, and late knowledge of the order; the delay was treated as supported by sufficient cause and condoned. On treaty relief, freight from cargo moved on feeder vessels under slot charter or space charter arrangements was treated as part of profits from operation of ships under Article 8 of the India-Malaysia tax treaty because the feeder leg was inextricably linked to the overall shipping voyage. Treaty protection was therefore available for the attributable freight income.</description>
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      <description>A 471-day delay in filing the appeal was explained by the assessee&#039;s foreign status, lack of office or employees in India, service at an old agent address, and late knowledge of the order; the delay was treated as supported by sufficient cause and condoned. On treaty relief, freight from cargo moved on feeder vessels under slot charter or space charter arrangements was treated as part of profits from operation of ships under Article 8 of the India-Malaysia tax treaty because the feeder leg was inextricably linked to the overall shipping voyage. Treaty protection was therefore available for the attributable freight income.</description>
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