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)
Summary of the Input Service Distributor (ISD) Mandate
The document provides an FAQ-style overview of the Input Service Distributor (ISD) mechanism, which will become mandatory under GST regulat...
-
In this post, I will discuss Secretarial Standards related to Proxies under SS – 2. Right to Appoint: A Member entitled to attend and ...
-
Particulars in Part 1 and Part 2 of Step-2 of registration form are required to be exactly the same as reported in the TDS statement. Plea...
-
1. Situation I. Tax Department Summons An employee received a summons from the tax department demanding an explanation for failing to discl...
-
The taxation of transactions within a Hindu Undivided Family (HUF) is governed by specific provisions under the Income Tax Act, 1961. This...
-
LEASE-DEED (A brief Introduction) Lease defined. A lease of immovable property is a transfer of a right to enjoy such property, mad...
-
Summary of the relevant updates is provided below for ease of your reference: A) Proposals relating to GST law, Compliances an...
-
This Tax Alert summarizes a recent decision of the Special Bench (SB) of the Ahmedabad Income-tax Appellate Tribunal (ITAT), in the case o...
-
The Central Board of Direct Taxes (CBDT) has issued a press release providing clarifications on the newly introduced PAN 2.0 system. Among...
-
A. Introduction: Section 270A of the Income Tax Act classifies variations in income into two categories: under-reporting and misreportin...
-
S No Due Date Related to Compliance to be made 1 11.12.20 24 GSTR ...
No comments:
Post a Comment