2013 (12) TMI 1106

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.... revenue is directed against the order dated 8.7.2011 of CIT for the assessment year 2008-09. The only dispute raised in this appeal is regarding assessment of income from inland haulage charges. 2. Facts in brief are that the assessee which is a non-resident company registered in Belgium was engaged in the business of operation of ships. The assessee had received certain inland haulage charges....

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....was observed by him that only loading, unloading and demurrages etc. were activities directly connected to shipping. It was also observed by him that the decision of the Tribunal in assessment year 2001-02 was against the stand taken by the department consistently in shipping cases. He, therefore, held that income from inland haulage charges was chargeable in India. The total terminal handling cha....

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....ges are only incidental and closely connected with the direct operations of the ship and hence, covered under the Article-8 of DTAA. CIT(A) therefore deleted the addition made by the AO aggrieved by which the revenue is in appeal before the Tribunal. 3. We have heard both parties, perused the records and considered the matter carefully. The dispute raised in this appeal is regarding assessment ....