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    <title>2019 (7) TMI 123 - ITAT MUMBAI</title>
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    <description>Freight receipts from feeder vessels were treated as income from the operation of ships in international traffic and, under Article 8 of the India-Germany DTAA, were held not taxable in India merely because the assessee&#039;s own vessels did not carry the cargo throughout. Earlier tribunal orders and the jurisdictional High Court had already upheld this view, so the addition on freight receipts was deleted. The challenge to initiation of penalty proceedings was treated as premature in light of the relief on the main addition and was not examined on merits.</description>
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      <description>Freight receipts from feeder vessels were treated as income from the operation of ships in international traffic and, under Article 8 of the India-Germany DTAA, were held not taxable in India merely because the assessee&#039;s own vessels did not carry the cargo throughout. Earlier tribunal orders and the jurisdictional High Court had already upheld this view, so the addition on freight receipts was deleted. The challenge to initiation of penalty proceedings was treated as premature in light of the relief on the main addition and was not examined on merits.</description>
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