https://www.taxtmi.com/caselaws?id=59724 Article 8 of the India-Brazil DTAA limits shipping relief to transportation carried on by the enterprise as owner, lessee or charterer of the relevant vessels. Freight from feeder-vessel operations did not qualify because the assessee was not the owner, lessee or charterer of those vessels, so that segment was excluded from treaty exemption. Profits from mother-vessel operations under a consortium or pool arrangement could fall within Article 8, but only if the cargo movement through qualifying vessels was verified on the record. Treaty relief was therefore confined to qualifying vessel operations, with factual verification required for the remaining segment. en-us Tue, 25 Nov 2008 00:00:00 +0530 Wed, 06 Dec 2023 19:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59724 Article 8 of the India-Brazil DTAA limits shipping relief to transportation carried on by the enterprise as owner, lessee or charterer of the relevant vessels. Freight from feeder-vessel operations did not qualify because the assessee was not the owner, lessee or charterer of those vessels, so that segment was excluded from treaty exemption. Profits from mother-vessel operations under a consortium or pool arrangement could fall within Article 8, but only if the cargo movement through qualifying vessels was verified on the record. Treaty relief was therefore confined to qualifying vessel operations, with factual verification required for the remaining segment. Case-Laws Income Tax Tue, 25 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59724