2015 (8) TMI 1018

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..... he respondent-assessee and against the revenue by the decision of this court rendered in the matter of Director of Income Tax v. Balaji Shipping UK Ltd. [2012 (8) TMI 681 - BOMBAY HIGH COURT] wherein held that income from utilizing slot hire facilities as availing of in these cases would fall within Article 9(1) for slot hires have a closer nexus, connection and relationship to the actual operatio .....

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..... India and Belgium and therefore not liable for tax in India? b) Whether Article 8(2)(b)(ii) and 8(2)(c) of the tax treaty between India and Belgium includes within its ambit and activity of inland transportation of cargo from various places within India? 3 The Advocates for the parties state that the issue arising in these appeals stand covered in favour of the respondent-assessee and again .....

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