Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (11) TMI 1925 - AT - Income TaxAssessment u/s 172(4) - freight beneficiary - CIT-A denying Appellant the benefit of the Agreement for Avoidance of Double Tax between India and Singapore - whether CIT (A) erred in not directing ITO to assess the income as nil of freight beneficiary i.e. BP Singapore Pte Ltd. while losing sight of the fact that BP Singapore Pte Ltd. is a Singapore tax resident company engaged in operation of ships in international traffic and hence entitled to benefit of Article 8 of the DTAA and their income from operation of ships in international traffic cannot be taxed in India? - HELD THAT:- Learned representatives fairly agree that whatever we decide in the case of BP Singapore Pte Ltd [2017 (11) TMI 1924 - ITAT RAJKOT] will be equally applicable here as well.
|