https://www.taxtmi.com/caselaws?id=285195 Receipts representing allocation or reimbursement of IT support costs used in shipping operations were treated as part of the business arrangement, not independent managerial, technical or consultancy services, because they carried no mark-up or profit element and were integrally connected with the shipping activity. Inland haulage charges were likewise held to be an integral and ancillary part of carriage in international traffic, arising from a composite shipping arrangement and not severable for separate domestic taxation. The treaty framework therefore prevailed over domestic taxation provisions, and both categories of receipts remained covered by treaty-protected shipping operations. en-us Wed, 07 Feb 2018 00:00:00 +0530 Wed, 01 Jan 2020 16:18:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285195 Receipts representing allocation or reimbursement of IT support costs used in shipping operations were treated as part of the business arrangement, not independent managerial, technical or consultancy services, because they carried no mark-up or profit element and were integrally connected with the shipping activity. Inland haulage charges were likewise held to be an integral and ancillary part of carriage in international traffic, arising from a composite shipping arrangement and not severable for separate domestic taxation. The treaty framework therefore prevailed over domestic taxation provisions, and both categories of receipts remained covered by treaty-protected shipping operations. Case-Laws Income Tax Wed, 07 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285195