Receipts from operation of ships in international traffic is exempt in terms of India-Singapore DTAA

Tata NYK Shipping Pvt Ltd Vs DCIT (ITAT Delhi) ITAT Delhi held that as per Article 8 of India–Singapore DTAA receipts from operation of ships and aircrafts in international traffic is taxable in the country of residence of the recipient. Therefore, amounts received by the assessee from operation of ships in international traffic would be exempt. Facts- The issue involved in the present appeal is that the revenue taxed the amount received by the assessee as income from royalty holding that there was no commercial rationale for incorporation of the appellant company in Singapore, the appellant...