https://www.taxtmi.com/caselaws?id=461929 Inland Haulage Charges directly connected with international shipping operations fall within the Article 8 exemption under the India-UAE DTAA and are not taxable in India. The jurisdictional High Court precedent on ancillary inland transportation supports this treatment despite revenue concerns that the wider legal question remains open. Where shipping income is exempt, dependent-agent permanent establishment and profit-attribution issues become academic. TDS credit relating to freight collections through an Indian agent requires verification under applicable rules and CBDT guidance, with the taxpayer given an opportunity to substantiate the claim. Interest under section 234D is consequential, while a challenge to initiation of penalty proceedings under section 270A is premature. en-us Wed, 16 Nov 2022 00:00:00 +0530 Thu, 08 May 2025 18:55:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461929 Inland Haulage Charges directly connected with international shipping operations fall within the Article 8 exemption under the India-UAE DTAA and are not taxable in India. The jurisdictional High Court precedent on ancillary inland transportation supports this treatment despite revenue concerns that the wider legal question remains open. Where shipping income is exempt, dependent-agent permanent establishment and profit-attribution issues become academic. TDS credit relating to freight collections through an Indian agent requires verification under applicable rules and CBDT guidance, with the taxpayer given an opportunity to substantiate the claim. Interest under section 234D is consequential, while a challenge to initiation of penalty proceedings under section 270A is premature. Case-Laws Income Tax Wed, 16 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461929