Time Charter Vessel Receipts Not Taxable as Royalties u/s 9(1)(vi), ITAT Rules; Control Remains with Owner.

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....Taxability of receipts on hire of vessel on a time charter basis - Royalty receipts u/s 9(1)(vi) - Addition on the ground that Charter has option of making structural alterations to the vessel and therefore, the charterer has specific control upon the vessel for its business activities. - ITAT dismissed the argument, as the clause also stated that the vessel would be returned to its original condition at the charterer's expense and the repairs could also be undertaken by the assessee. Therefore, the vessel was under the exclusive control and command of the assessee throughout the operation, navigation, and management. - AT....