Mauritius Company's Shipping Income Not Taxable in India Without Permanent Establishment, Says Court u/s 44B.

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....Income accrued in India - now when the assessee has been held as an agent of independent status, and the income of M/s Arc Line, Mauritius in the absence of any PE in India had been held as not taxable in India, therefore, there remains no basis for taxing the income of M/s Arc Line, Mauritius from its shipping activities under Sec. 44B of the Act in the hands of the assessee by treating it as a representative assessee of the aforesaid company. - AT....