ships

Advance Ruling on taxability of profits from international operations of ships

The applicant is a non-resident shipping Company incorporated under the laws of Switzerland and is in the business of shipping contracts for the transportation of cargo worldwide. During the financial years 2007-08 and 2008-09, the applicant entered into a shipping contract for transportation of cargo from Indian ports to China. The amount of freight for transportation of cargo from the Indian port to a port outside India was invoiced and received by the applicant.
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Payments for technical services are to be treated as ‘fees for technical services’ under Article 13(4) of Indo-French DTAA

For the purposes of paragraph 2 of this Article, and subject to paragraph 5 of this Article, the term 'fees for technical services' means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including the provision of services of technical or other personnel) which:
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Interpretation of Accounting Standard’s issued by ICAI in brief

Chapter III of the Income-tax Act, 1961 (hereinafter referred to as the ‘Act’) deals with incomes which do not form part of total income. Sections 10A and 10B of the Act are covered under Chapter III. These sections allow certain deductions, for certain years, from the total income of an assessee. These deductions are commonly described as ‘tax holiday’ and the period during which these deductions are available is commonly described as ‘tax holiday period’.
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