This Tax Alert summarizes a recent decision of the Pune Income Tax Appellate Tribunal (Tribunal) in the case of Shaan Marine Services Pvt. Ltd. (Taxpayer). The issue before the Tribunal was whether freight income of a Cyprus shipping company (Ship Co) was taxable in India as per the provisions of the India-Cyprus Double Taxation Avoidance Agreement (Cyprus DTAA). The Tribunal, on consideration of the facts and the specific language of the Cyprus DTAA, held that Ship Co was not a “paper company” and its “effective management” was situated in Cyprus as it was registered and headquartered in Cyprus. Hence, Ship Co is entitled to benefits of the Cyprus DTAA and its income from transportation of cargo is not taxable in India.
Subscribe to:
Post Comments (Atom)
HC holds unutilised CGST and IGST credit can be transferred on business transfer between distinct persons
This Tax Alert summarizes a recent ruling of the Andhra Pradesh High Court (HC) [1] on the Goods and Services Tax (GST) implications on b...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
01. No change in Income Tax rates, surcharge & cess. 02. Income tax Act 2025 effective from April 1, 2026. 03. Old regime tax ...
-
01. The present employer contribution is restricted to 12%. 02. In the proposal the 12% limit removed 03. It means employer contri...
-
The posting had been move to another website. Please click the link below to get the access of the same. https://taxofindia.wordpress....
-
The Central Board of Direct Taxes (CBDT) released the Draft Income Tax Rules, 2026 on February 7, 2026. It has invited suggestions and opi...
-
Introduction Employee welfare is a cornerstone of corporate responsibility, and gratuity forms a critical part of the social security benefi...
-
At first glance, DGFT Public Notice No. 42/2025-26 appears to be a mundane update—just three new fields to populate on the electronic ...
-
In a recent and noteworthy ruling, the Hon’ble Delhi Income Tax Appellate Tribunal has provided important clarity on the scope of appellat...
-
A tax investigation is one of the most stressful events a company can face. It disrupts operations, consumes resources, and carries signific...
-
This is to update you about an important decision by Hon’ble Madras High Court (‘ HC ’/’ Court ’) in the case of ARS Steel and Alloy Inte...
No comments:
Post a Comment