https://www.taxtmi.com/caselaws?id=273315 Cost reimbursements for an integrated SAP-based ERP system used in global shipping operations were treated as part of income from operations of ships in international traffic, because the receipts were on a cost-to-cost basis, without markup, and did not involve independent managerial, technical, or consultancy services; they were therefore not taxable as royalty or fees for technical services. Inland haulage charges were also held to be intrinsically connected with international shipping, as an ancillary part of container and cargo movement, so the treaty protection for shipping income prevailed over domestic charging provisions and the amounts were not separately taxable in India. en-us Wed, 15 Feb 2017 00:00:00 +0530 Sat, 16 Jun 2018 11:06:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273315 Cost reimbursements for an integrated SAP-based ERP system used in global shipping operations were treated as part of income from operations of ships in international traffic, because the receipts were on a cost-to-cost basis, without markup, and did not involve independent managerial, technical, or consultancy services; they were therefore not taxable as royalty or fees for technical services. Inland haulage charges were also held to be intrinsically connected with international shipping, as an ancillary part of container and cargo movement, so the treaty protection for shipping income prevailed over domestic charging provisions and the amounts were not separately taxable in India. Case-Laws Income Tax Wed, 15 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273315