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2014 (7) TMI 725 - HC - Income TaxInterpretation of Article 8 of Indo-Belgium DTAA – Income from inland Haulage Charges - Whether the tax treaty between India and Belgium includes within its Ambit the activity of Inland Transport of Cargo from various places within India – Held that:- The Assessee collected Inland Haulage Charges from it’s customers in respect of transportation of goods from Inland Container Depots (ICDs) to the Port where the goods were loaded in the ships for international traffic - assessee had received Inland Haulage Charges from its clients and the same were included in receipts under the head “permanent handling charges” - Assessee claimed that Inland Haulage Charges are part of its shipping business and are in the nature of “handling charges” and are therefore covered by phrase “any other amount of similar nature” mentioned in the explanation to section 44B of the Act. Such charges were part of the shipping business of the Assessee, they were therefore eligible for DIT relief, was the submission of the Assessee - The decision in Director of Income-tax (International Taxation) Versus Balaji Shipping UK Ltd. [2012 (8) TMI 681 - BOMBAY HIGH COURT] followed – no substantial question of law arises for consideration – Decided against Revenue.
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