https://www.taxtmi.com/caselaws?id=443794 Receipts from voyage charter operations in international traffic were treated as shipping income under the treaty, not as royalty. The tribunal considered the assessee's Singapore residence, treaty entitlement, shipping assets, and the absence of evidence of any sham, back-to-back, or conduit arrangement. On that factual record, the Revenue's attempt to recharacterise the income as royalty was rejected, and the treaty-based shipping income treatment was upheld. The assessment addition for royalty classification therefore failed, with relief granted on the substantive tax issue. en-us Wed, 07 Jun 2023 00:00:00 +0530 Tue, 03 Oct 2023 08:38:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443794 Receipts from voyage charter operations in international traffic were treated as shipping income under the treaty, not as royalty. The tribunal considered the assessee's Singapore residence, treaty entitlement, shipping assets, and the absence of evidence of any sham, back-to-back, or conduit arrangement. On that factual record, the Revenue's attempt to recharacterise the income as royalty was rejected, and the treaty-based shipping income treatment was upheld. The assessment addition for royalty classification therefore failed, with relief granted on the substantive tax issue. Case-Laws Income Tax Wed, 07 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443794