https://www.taxtmi.com/caselaws?id=58919 Hire charges for a specialised anchor-handling tug used exclusively for offshore platform construction in connection with oil exploration were treated as income directly connected with oil exploration operations and covered by section 44BB. The vessel was not regarded as an ordinary ship engaged in shipping operations, so article 9 of the applicable tax treaty was rejected. Instead, the income was considered business profits under article 7; as the non-resident had no permanent establishment in India, the profits were not taxable in India and no tax deduction from the remittance was required. en-us Fri, 30 Sep 1994 00:00:00 +0530 Wed, 22 Dec 2010 17:57:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58919 Hire charges for a specialised anchor-handling tug used exclusively for offshore platform construction in connection with oil exploration were treated as income directly connected with oil exploration operations and covered by section 44BB. The vessel was not regarded as an ordinary ship engaged in shipping operations, so article 9 of the applicable tax treaty was rejected. Instead, the income was considered business profits under article 7; as the non-resident had no permanent establishment in India, the profits were not taxable in India and no tax deduction from the remittance was required. Case-Laws Income Tax Fri, 30 Sep 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58919