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2018 (8) TMI 855 - AT - Income TaxExigibility of tax of the profits of the assessee from the operation of ships in international traffic - Article-22 of DTAA - the phrase “other than the profits from the operation of the ships in international traffic” occurring in Article-7 - Double Taxation Avoidance Agreement between India and Switzerland ('Tax Treaty') - Held that:- the issue involved in revenue’s appeal is squarely covered in favour of the assessee by a series of the decision of the ITAT in assessee’s own case. - Respectfully following the precedent, the appeals filed by the Revenue are dismissed. - Decided against the revenue.
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