https://www.taxtmi.com/caselaws?id=439002 Time charter receipts for a vessel were held not to constitute royalty under section 9(1)(vi) and the India-Singapore DTAA because the owner retained control, navigation and management, and the charterer received services rather than use or right to use the vessel. The linked reimbursement of expenses was also not royalty, as it followed the same charter arrangement. Interest under section 234A was remanded for factual verification of return filing timeliness, interest under section 234B was consequential, and initiation of penalty under section 270A was treated as premature. The principal royalty additions were deleted, with only partial relief granted. en-us Mon, 12 Jun 2023 00:00:00 +0530 Mon, 18 Sep 2023 11:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439002 Time charter receipts for a vessel were held not to constitute royalty under section 9(1)(vi) and the India-Singapore DTAA because the owner retained control, navigation and management, and the charterer received services rather than use or right to use the vessel. The linked reimbursement of expenses was also not royalty, as it followed the same charter arrangement. Interest under section 234A was remanded for factual verification of return filing timeliness, interest under section 234B was consequential, and initiation of penalty under section 270A was treated as premature. The principal royalty additions were deleted, with only partial relief granted. Case-Laws Income Tax Mon, 12 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439002