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    <title>2021 (8) TMI 1355 - ITAT MUMBAI</title>
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    <description>Article 8 treaty protection for shipping income was treated as extending to freight receipts arising under pooling and joint business arrangements, including collections linked to feeder vessels and other covered shipments. The Tribunal also noted that a jurisdictional High Court ruling on the issue remained binding on it unless reversed, and that the mere pendency of an SLP before the Supreme Court did not reduce that binding force. On that basis, the restrictive approach below was not sustained and the treaty benefit was applied to the entire freight receipts.</description>
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      <description>Article 8 treaty protection for shipping income was treated as extending to freight receipts arising under pooling and joint business arrangements, including collections linked to feeder vessels and other covered shipments. The Tribunal also noted that a jurisdictional High Court ruling on the issue remained binding on it unless reversed, and that the mere pendency of an SLP before the Supreme Court did not reduce that binding force. On that basis, the restrictive approach below was not sustained and the treaty benefit was applied to the entire freight receipts.</description>
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