<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2022 (11) TMI 1554 - ITAT MUMBAI</title>
    <link>https://www.taxtmi.com/caselaws?id=461929</link>
    <description>Inland Haulage Charges connected with international shipping are treated as exempt under Article 8 of the India-UAE DTAA, following the binding Bombay High Court ruling in Safmarine Container Lines N.V.; the article notes that the Tribunal therefore rejected the Revenue&#039;s attempt to tax a part of such receipts. Because the shipping income was held exempt, the dependent agent PE issue was treated as academic. On TDS credit, the matter was restored for verification and credit where duly supported, including amounts reflected through an Indian agent&#039;s PAN. Interest under section 234D was treated as consequential, while initiation of penalty proceedings under section 270A was regarded as premature.</description>
    <language>en-us</language>
    <pubDate>Wed, 16 Nov 2022 00:00:00 +0530</pubDate>
    <lastBuildDate>Thu, 08 May 2025 18:55:19 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=820530" rel="self" type="application/rss+xml"/>
    <item>
      <title>2022 (11) TMI 1554 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=461929</link>
      <description>Inland Haulage Charges connected with international shipping are treated as exempt under Article 8 of the India-UAE DTAA, following the binding Bombay High Court ruling in Safmarine Container Lines N.V.; the article notes that the Tribunal therefore rejected the Revenue&#039;s attempt to tax a part of such receipts. Because the shipping income was held exempt, the dependent agent PE issue was treated as academic. On TDS credit, the matter was restored for verification and credit where duly supported, including amounts reflected through an Indian agent&#039;s PAN. Interest under section 234D was treated as consequential, while initiation of penalty proceedings under section 270A was regarded as premature.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 16 Nov 2022 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=461929</guid>
    </item>
  </channel>
</rss>