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2008 (11) TMI 433 - AT - Income TaxDouble Taxation Avoidance Agreement (DTAA) - Taxability of income derived from operation of ships - Whether the assessee would be entitled to benefits of DTAA between India and France in respect of income received from use of ship on slot arrangement basis - CIT(A) held that the receipts from use of vessels on slot arrangement basis would also been entitled for relief under article 9 of DTAA. HELD THAT:- From persual of AO's order, It is clear that the AO had applied the provisions of Article 9 of DTAA and had denied benefit only in respect of income pertaining to slot arrangements adopting a particular interpretation of the meaning of the phrase ‘operation of ship’. Therefore, we uphold the order of the CIT(A). In the result the appeal of the revenue is dismissed.
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