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2023 (10) TMI 17 - AT - Income TaxIncome accrued in India - receipts from international traffic pertaining to voyage chartered as ‘Royalty’ - treaty benefits under DTAA - HELD THAT:- As the assessee is entitled to treaty benefit after examination of the tax returns of the assessee filed before the tax authority of Singapore and also held that the assessee is to be considered as the tax resident of Singapore. The Tribunal has also held that the assessee has not entered into any back- to-back arrangement. The Tribunal has also held that the receipts cannot be treated as royalty. Hence, in the absence of any change in the business pattern or the judicial proposition, we hold that the revenue erred in treating the receipts from international traffic pertaining to voyage chartered as ‘Royalty’. Decided in favour of assessee.
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