https://www.taxtmi.com/caselaws?id=471787 Article 8 of the India-Malaysia DTAA assigns taxing rights over profits from operating ships in international traffic to the residence State. Its scope encompasses cargo transportation undertaken by ship owners, lessees, or charterers. Freight earned through feeder-vessel arrangements, materially equivalent to slot-hire arrangements, consequently forms part of international shipping profits. In the absence of contrary facts or legal position, such freight income is not taxable in India and is governed by Article 8. en-us Wed, 09 Apr 2025 00:00:00 +0530 Thu, 17 Sep 2026 18:59:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471787 Article 8 of the India-Malaysia DTAA assigns taxing rights over profits from operating ships in international traffic to the residence State. Its scope encompasses cargo transportation undertaken by ship owners, lessees, or charterers. Freight earned through feeder-vessel arrangements, materially equivalent to slot-hire arrangements, consequently forms part of international shipping profits. In the absence of contrary facts or legal position, such freight income is not taxable in India and is governed by Article 8. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471787