https://www.taxtmi.com/caselaws?id=308313 Receipts ancillary and inextricably linked to international shipping operations were treated as covered by Article 9 of the India-France DTAA, so inland haulage charges and feeder-vessel freight were not separately taxable in India and the related additions were deleted. The Indian agent was not regarded as an agency permanent establishment because it was remunerated at arm's length, so no PE was held to exist. The IT support services income was not finally decided on merits and was remitted for fresh factual examination. Interest under sections 234B and 234C was consequential to the substantive outcome. en-us Mon, 16 Jan 2023 00:00:00 +0530 Wed, 14 Jun 2023 21:50:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308313 Receipts ancillary and inextricably linked to international shipping operations were treated as covered by Article 9 of the India-France DTAA, so inland haulage charges and feeder-vessel freight were not separately taxable in India and the related additions were deleted. The Indian agent was not regarded as an agency permanent establishment because it was remunerated at arm's length, so no PE was held to exist. The IT support services income was not finally decided on merits and was remitted for fresh factual examination. Interest under sections 234B and 234C was consequential to the substantive outcome. Case-Laws Income Tax Mon, 16 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308313