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 relevan

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