https://www.taxtmi.com/caselaws?id=441306 Freight earned from a vessel voyage was analysed under the India-Singapore DTAA to determine whether it formed part of international traffic and was taxable only in Singapore. On the charter party, port clearance records, residency material and the Singapore assessment record, the freight beneficiary was treated as a Singapore resident and the voyage income had been offered to tax there. The contention that the movement was only a coastal run was rejected because the voyage formed part of a broader international journey through Indian ports. Accordingly, treaty protection applied and the addition under section 172(4) was unsustainable. en-us Wed, 02 Aug 2023 00:00:00 +0530 Tue, 02 Jan 2024 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441306 Freight earned from a vessel voyage was analysed under the India-Singapore DTAA to determine whether it formed part of international traffic and was taxable only in Singapore. On the charter party, port clearance records, residency material and the Singapore assessment record, the freight beneficiary was treated as a Singapore resident and the voyage income had been offered to tax there. The contention that the movement was only a coastal run was rejected because the voyage formed part of a broader international journey through Indian ports. Accordingly, treaty protection applied and the addition under section 172(4) was unsustainable. Case-Laws Income Tax Wed, 02 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441306