https://www.taxtmi.com/caselaws?id=59721 The Tribunal upheld the CIT(A)'s decision, determining that the assessee, a non-resident UK company, was eligible for the benefits of Article 9 of the Indo-U.K. Treaty. It concluded that freight income from transportation of cargo in international traffic, including slot chartering arrangements, should be taxed only in the State of residence, thus exempt from Indian taxation. The Tribunal dismissed the revenue's appeals and the assessee's cross-objections, affirming that the term "operation of ships" includes slot chartering, aligning with the OECD commentary and the treaty's original intent. en-us Wed, 13 Aug 2008 00:00:00 +0530 Sun, 10 Dec 2023 15:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59721 The Tribunal upheld the CIT(A)'s decision, determining that the assessee, a non-resident UK company, was eligible for the benefits of Article 9 of the Indo-U.K. Treaty. It concluded that freight income from transportation of cargo in international traffic, including slot chartering arrangements, should be taxed only in the State of residence, thus exempt from Indian taxation. The Tribunal dismissed the revenue's appeals and the assessee's cross-objections, affirming that the term "operation of ships" includes slot chartering, aligning with the OECD commentary and the treaty's original intent. Case-Laws Income Tax Wed, 13 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59721