Advance Ruling on taxability of profits from international operations of ships

Facts 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. For the relevant years the applicant appointed a port agent in India for handing the cargo. The port agent on behalf of the...