https://www.taxtmi.com/caselaws?id=429955 Income from inland haulage charges and freight earned through feeder vessels was treated as shipping income connected with operations of ships in international traffic and, under Article 9 of the India-France DTAA, was held not taxable in India. The Tribunal also applied its earlier view that an Indian agent remunerated at arm's length does not ordinarily constitute an agency permanent establishment, and the PE finding was set aside. An additional treaty-based ground on IT support services was admitted because it required factual examination and was remanded to the Assessing Officer for de novo consideration. en-us Thu, 03 Nov 2022 00:00:00 +0530 Tue, 08 Nov 2022 08:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429955 Income from inland haulage charges and freight earned through feeder vessels was treated as shipping income connected with operations of ships in international traffic and, under Article 9 of the India-France DTAA, was held not taxable in India. The Tribunal also applied its earlier view that an Indian agent remunerated at arm's length does not ordinarily constitute an agency permanent establishment, and the PE finding was set aside. An additional treaty-based ground on IT support services was admitted because it required factual examination and was remanded to the Assessing Officer for de novo consideration. Case-Laws Income Tax Thu, 03 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429955