https://www.taxtmi.com/caselaws?id=438400 Reassessment under section 147 was held to require tangible material showing escapement of income in the assessee's hands; a mere higher tax rate could not justify jurisdiction where the receipts had already been taxed in the Indian agent's hands. Documentation charges and vessel handling charges were treated as independent receipts of the agent, not income accruing to the assessee in India, and double taxation was avoided. Shipping freight income was held to fall within Article 8 of the India-Singapore DTAA, which allocates exclusive taxing rights to the State of residence; Article 24 was inapplicable because the Singapore tax treatment was on an accrual basis, not a remittance or receipt basis. en-us Thu, 04 May 2023 00:00:00 +0530 Mon, 08 Sep 2025 14:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438400 Reassessment under section 147 was held to require tangible material showing escapement of income in the assessee's hands; a mere higher tax rate could not justify jurisdiction where the receipts had already been taxed in the Indian agent's hands. Documentation charges and vessel handling charges were treated as independent receipts of the agent, not income accruing to the assessee in India, and double taxation was avoided. Shipping freight income was held to fall within Article 8 of the India-Singapore DTAA, which allocates exclusive taxing rights to the State of residence; Article 24 was inapplicable because the Singapore tax treatment was on an accrual basis, not a remittance or receipt basis. Case-Laws Income Tax Thu, 04 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438400