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    <title>1994 (4) TMI 25 - GUJARAT High Court</title>
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    <description>The court ruled in favor of the petitioners, holding that the income from shipping operations in India was non-taxable under Article 9 of the Double Taxation Avoidance Agreement (DTAA) between India and the UK. It was held that the provisions of the DTAA would prevail over the general provisions of the Income-tax Act, rendering the actions of the Income-tax Officer in levying tax and imposing penalties on the petitioner-company invalid. The court also found that the Income-tax Officer lacked jurisdiction to question the genuineness of the petitioner-company, as it had provided relevant certificates confirming its incorporation and tax residency status. The petition was allowed, and the order of the Income-tax Officer was quashed and set aside.</description>
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    <pubDate>Wed, 06 Apr 1994 00:00:00 +0530</pubDate>
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      <title>1994 (4) TMI 25 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=19497</link>
      <description>The court ruled in favor of the petitioners, holding that the income from shipping operations in India was non-taxable under Article 9 of the Double Taxation Avoidance Agreement (DTAA) between India and the UK. It was held that the provisions of the DTAA would prevail over the general provisions of the Income-tax Act, rendering the actions of the Income-tax Officer in levying tax and imposing penalties on the petitioner-company invalid. The court also found that the Income-tax Officer lacked jurisdiction to question the genuineness of the petitioner-company, as it had provided relevant certificates confirming its incorporation and tax residency status. The petition was allowed, and the order of the Income-tax Officer was quashed and set aside.</description>
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      <pubDate>Wed, 06 Apr 1994 00:00:00 +0530</pubDate>
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