Income from time charter services rendered by vessel cannot be treated as ‘royalty‘

Smit Singapore Pte Ltd. Vs DCIT (ITAT Mumbai) Assessee had received charges on account of time charter services rendered by its vessel ‘Smit Borneo‘ along with the crew to Leighton India Contractor Pvt. Ltd., and not for allowing the latter the ‘use‘ or ‘right to use‘ of industrial, commercial, or scientific equipment, the same therein cannot be treated as ‘royalty‘ within the meaning of Article 12(3)(b) of the India-Singapore tax treaty. As such, we herein not being able to subscribe to the view taken by the lower authorities, to the extent they had concluded t...