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    <title>2025 (8) TMI 747 - ITAT MUMBAI</title>
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    <description>Income from slot hire and feeder vessel arrangements was treated as integrally connected with the operation of ships in international traffic, so relief under Article 8 of the India-Germany DTAA was available and the corresponding addition under section 44B was deleted. The Tribunal followed binding jurisdictional precedents and held that the character of the receipts did not change merely because the main vessels could not directly call at Indian ports. The claim for TDS credit, however, depended on verification of the TDS statements and matching with assessed income, so that issue was remitted to the Assessing Officer for examination and recomputation.</description>
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