2020 (1) TMI 1747

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....la i/b. PDS Legal PC : Heard the learned counsel for the parties. 2. The appeal pertains to the assessment year 2011-12. The Appellant- Revenue has urged the following questions for our consideration: a) "Whether on the facts and the circumstances of the case and in law the income of the assessee by way of slot chartering would form a part of income from operation of ship exempt ....

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....9;containers', both of which are conspicuously absent in IndiaGerman treaty and thereby differentiable from the case of M/s Balaji Shipping UK?" d) "Whether on the facts and the circumstances of the case and in law, the ITAT erred in concluding that slot chartering is ancillary activities to operation of ship and this included within the meaning of 'operation of ships' when ne....

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....y the following question of law for our consideration: "Whether on the facts and in the circumstance of the case and in law, the income of the assessee by way of slot chartering would from a part of income from operations of ships exempt under Article 8 of the DTAA?" 3 We find that the impugned order of the Tribunal has allowed the Respondent's appeal by following the decisio....