https://www.taxtmi.com/caselaws?id=59721 The treaty phrase "operation of ships" was construed by reference to contemporaneous international understanding and OECD commentary because it was not defined in the treaty or then-applicable domestic law. On that basis, freight income from slot chartering and feeder-vessel arrangements, being directly connected with international shipping operations, fell within Article 9(1) of the Indo-UK Treaty and was taxable only in the State of residence. Article 9(4) was also read broadly: income from the use of containers employed as an integral part of transport of goods was covered, even though "use" was not confined to rental or lease. The treaty benefit therefore extended to the disputed shipping and container receipts. 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 treaty phrase "operation of ships" was construed by reference to contemporaneous international understanding and OECD commentary because it was not defined in the treaty or then-applicable domestic law. On that basis, freight income from slot chartering and feeder-vessel arrangements, being directly connected with international shipping operations, fell within Article 9(1) of the Indo-UK Treaty and was taxable only in the State of residence. Article 9(4) was also read broadly: income from the use of containers employed as an integral part of transport of goods was covered, even though "use" was not confined to rental or lease. The treaty benefit therefore extended to the disputed shipping and container receipts. Case-Laws Income Tax Wed, 13 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59721