Hire Charges of vessel did not constitute ‘Royalty’ under India-Singapore DTAA as it was business income

Kreuz Challenger Pte Ltd. Vs ACIT (ITAT Delhi)

Conclusion: Hire charges of a vessel did not constitute ‘Royalty’ as it was in the nature of business income and as there was no Permanent Establishment therefore, no taxability arose on account of business income. Merely because of the fact that assessee had applied for lower deduction certificate u/s 197, that in itself could not be a basis for imposing a tax liability as no admission against the interest of person was conclusive as far as it could be explained.

Held: AO observed that the

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