https://www.taxtmi.com/caselaws?id=199278 Receipts for shared global tracking system costs were treated as profits derived from the operation of ships in international traffic under the India-Denmark DTAA, because the same treaty classification had already been applied in the assessee's earlier year on identical facts and no distinguishing feature was shown. The amounts were therefore not characterised as fees for technical services or royalty. Interest on income-tax refund under section 244A was treated as interest covered by the DTAA's interest article, rather than as shipping income under the shipping article. The treaty characterisation was thus maintained separately for each receipt type, and the prior appellate view was sustained on both issues. en-us Fri, 14 Dec 2012 00:00:00 +0530 Mon, 18 Jun 2018 10:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=199278 Receipts for shared global tracking system costs were treated as profits derived from the operation of ships in international traffic under the India-Denmark DTAA, because the same treaty classification had already been applied in the assessee's earlier year on identical facts and no distinguishing feature was shown. The amounts were therefore not characterised as fees for technical services or royalty. Interest on income-tax refund under section 244A was treated as interest covered by the DTAA's interest article, rather than as shipping income under the shipping article. The treaty characterisation was thus maintained separately for each receipt type, and the prior appellate view was sustained on both issues. Case-Laws Income Tax Fri, 14 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=199278