https://www.taxtmi.com/caselaws?id=300475 Freight income from feeder vessels and slot hire arrangements was treated as profits from operation of ships in international traffic and, on the Tribunal's consistent view in the assessee's earlier years, was held eligible for relief under Article 8 of the India-Germany DTAA and not taxable in India. The agency permanent establishment question and any further attribution were left open as academic. Following jurisdictional precedent, interest under section 234B was deleted because the non-resident's tax liability was governed by withholding provisions. The TDS credit claim was remanded to the Assessing Officer for factual verification and consequential grant, if due. en-us Fri, 31 Jan 2020 00:00:00 +0530 Fri, 04 Feb 2022 20:37:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300475 Freight income from feeder vessels and slot hire arrangements was treated as profits from operation of ships in international traffic and, on the Tribunal's consistent view in the assessee's earlier years, was held eligible for relief under Article 8 of the India-Germany DTAA and not taxable in India. The agency permanent establishment question and any further attribution were left open as academic. Following jurisdictional precedent, interest under section 234B was deleted because the non-resident's tax liability was governed by withholding provisions. The TDS credit claim was remanded to the Assessing Officer for factual verification and consequential grant, if due. Case-Laws Income Tax Fri, 31 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300475