Inland Haulage Charges covered under Article 9 of India-France Tax Treaty hence not taxable

CMA CGM SA Vs ACIT (ITAT Mumbai) ITAT Mumbai held that Inland Haulage Charges forms part of income from operation of ships in international traffic and hence covered under Article-9 of India-France Tax Treaty is not taxable in India. Facts- The assessee had collected a sum of Rs. 308,74,51,33 1, from its customers on account of IHC. These charges were collected towards transportation of goods from the exporter’s warehouse to the port of loading and vice versa. As per the assessee, the IHC activity is directly connected to and ancillary to the transportation of cargo in international traffic ...