https://www.taxtmi.com/caselaws?id=410751 Receipts from time charter of a vessel with crew were held not to be royalty under section 9(1)(vi) and Article 12 of the India-Singapore DTAA because the charterer obtained no independent use or right to use the equipment; the owner retained control and the arrangement was characterised as a service contract, so the royalty addition was deleted. Reimbursement of vessel-related expenses was not finally determined on the existing record and was remanded for limited factual verification. Additional TDS credit was also remanded for examination of the supporting documents and directed to be allowed after verification. en-us Tue, 20 Jul 2021 00:00:00 +0530 Sat, 07 Aug 2021 23:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410751 Receipts from time charter of a vessel with crew were held not to be royalty under section 9(1)(vi) and Article 12 of the India-Singapore DTAA because the charterer obtained no independent use or right to use the equipment; the owner retained control and the arrangement was characterised as a service contract, so the royalty addition was deleted. Reimbursement of vessel-related expenses was not finally determined on the existing record and was remanded for limited factual verification. Additional TDS credit was also remanded for examination of the supporting documents and directed to be allowed after verification. Case-Laws Income Tax Tue, 20 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410751