https://www.taxtmi.com/caselaws?id=390430 Receipts integrally connected with shipping operations in international traffic, including inland haulage charges and feeder-vessel freight, were treated as protected shipping income under Article 9 of the India-France DTAA and were not taxable in India. Service tax collected on inland haulage charges was also excluded from gross receipts for section 44B computation because the underlying income was treaty-protected. The Indian agent was not regarded as an agency permanent establishment, as it was remunerated at arm's length and the PE objection was academic in light of the treaty exemption. Related tax-computation and credit issues were left for rectification, and the penalty ground was rejected as premature. en-us Mon, 30 Dec 2019 00:00:00 +0530 Thu, 02 Jan 2020 17:24:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390430 Receipts integrally connected with shipping operations in international traffic, including inland haulage charges and feeder-vessel freight, were treated as protected shipping income under Article 9 of the India-France DTAA and were not taxable in India. Service tax collected on inland haulage charges was also excluded from gross receipts for section 44B computation because the underlying income was treaty-protected. The Indian agent was not regarded as an agency permanent establishment, as it was remunerated at arm's length and the PE objection was academic in light of the treaty exemption. Related tax-computation and credit issues were left for rectification, and the penalty ground was rejected as premature. Case-Laws Income Tax Mon, 30 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390430