https://www.taxtmi.com/caselaws?id=434977 A non-resident shipping company engaged in shipping income fell within the special assessment scheme under section 172, so the section 144C objection did not invalidate the assessment on the facts found. The company also satisfied India-UAE DTAA residence conditions because it was incorporated and licensed in Dubai, supported by commercial and banking documents, and held UAE tax residency certificates. The nationality of individual directors or partners was treated as immaterial to corporate residence where incorporation and management were in the UAE. On that basis, treaty relief under Article 8 for shipping income applied and the denial of exemption could not stand. en-us Mon, 06 Mar 2023 00:00:00 +0530 Thu, 09 Mar 2023 08:39:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434977 A non-resident shipping company engaged in shipping income fell within the special assessment scheme under section 172, so the section 144C objection did not invalidate the assessment on the facts found. The company also satisfied India-UAE DTAA residence conditions because it was incorporated and licensed in Dubai, supported by commercial and banking documents, and held UAE tax residency certificates. The nationality of individual directors or partners was treated as immaterial to corporate residence where incorporation and management were in the UAE. On that basis, treaty relief under Article 8 for shipping income applied and the denial of exemption could not stand. Case-Laws Income Tax Mon, 06 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434977