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    <title>2025 (10) TMI 944 - ITAT MUMBAI</title>
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    <description>Receipts derived from the operation of ships in international traffic were treated as covered by Article 8 of the India-UAE DTAA and therefore not taxable in India as business profits. The Tribunal followed earlier co-ordinate Bench rulings in the assessee&#039;s own case and held that freight income from the shipping chain, including feeder-vessel earnings, fell within the treaty exemption. Inland haulage charges were also held to be inextricably linked to the shipping operation and an integral part of the shipping business, so they could not be separately taxed under domestic law. The corresponding addition was deleted.</description>
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