https://www.taxtmi.com/caselaws?id=763185 Hire charges for a time-chartered offshore services vessel were examined under section 44BB of the Income-tax Act alongside the India-Singapore DTAA. The text states that section 44BB operates only as a computation provision, while sections 4, 5 and 9 continue to govern chargeability; in the absence of a permanent establishment in India, the treaty benefit was available. It also notes that the assessee had no office, branch, project office or liaison office in India, and that the lower deduction certificate under section 197 did not estop correct tax determination. On that basis, the hire charges were held not taxable under section 44BB and the addition was deleted. en-us Mon, 09 Dec 2024 00:00:00 +0530 Fri, 13 Dec 2024 14:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763185 Hire charges for a time-chartered offshore services vessel were examined under section 44BB of the Income-tax Act alongside the India-Singapore DTAA. The text states that section 44BB operates only as a computation provision, while sections 4, 5 and 9 continue to govern chargeability; in the absence of a permanent establishment in India, the treaty benefit was available. It also notes that the assessee had no office, branch, project office or liaison office in India, and that the lower deduction certificate under section 197 did not estop correct tax determination. On that basis, the hire charges were held not taxable under section 44BB and the addition was deleted. Case-Laws Income Tax Mon, 09 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763185