https://www.taxtmi.com/caselaws?id=767600 ITAT Chennai-AT held that hire charges for bareboat dredgers do not constitute royalty under India-Netherlands and India-Belgium DTAAs. The tribunal ruled that payments for use of industrial/commercial equipment are excluded from royalty definition per Article 12. The assessee had no business connection or permanent establishment in India, making attribution of profits inapplicable. Survey statements under Section 133A were deemed inconclusive evidence without cross-examination. The appeal was allowed, with income not taxable as royalty. en-us Tue, 25 Feb 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767600 ITAT Chennai-AT held that hire charges for bareboat dredgers do not constitute royalty under India-Netherlands and India-Belgium DTAAs. The tribunal ruled that payments for use of industrial/commercial equipment are excluded from royalty definition per Article 12. The assessee had no business connection or permanent establishment in India, making attribution of profits inapplicable. Survey statements under Section 133A were deemed inconclusive evidence without cross-examination. The appeal was allowed, with income not taxable as royalty. Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767600