https://www.taxtmi.com/caselaws?id=304955 Receipts ancillary to and integrally connected with shipping operations in international traffic were treated as shipping income covered by Article 9 of the India-France DTAA, so inland haulage charges and feeder vessel freight were held not taxable in India. The Indian agent, having been remunerated at arm's length under an APA and with no material factual change, was not treated as an agency permanent establishment. Additional grounds on IT support fees as fees for technical services were admitted because they raised a legal claim affecting taxable income, and the matter was remanded for fresh factual examination. en-us Fri, 02 Sep 2022 00:00:00 +0530 Mon, 07 Nov 2022 23:15:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304955 Receipts ancillary to and integrally connected with shipping operations in international traffic were treated as shipping income covered by Article 9 of the India-France DTAA, so inland haulage charges and feeder vessel freight were held not taxable in India. The Indian agent, having been remunerated at arm's length under an APA and with no material factual change, was not treated as an agency permanent establishment. Additional grounds on IT support fees as fees for technical services were admitted because they raised a legal claim affecting taxable income, and the matter was remanded for fresh factual examination. Case-Laws Income Tax Fri, 02 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304955