Inland haulage charges are in the nature of income from operations of ships in international traffic and not taxable in India per Article 8 of the India-Belgium tax treaty

DDIT M/s. Vodafone Essar Infrastructure Limited. Safmarine Container Lines NV, ITA No. 3073/Mum/10 (Mumbai ITAT) Facts :-Assessee, a company incorporated in Belgium, is engaged in the business of operations of ships in international traffic.During the course of scrutiny assessment proceedings, the Assessing Officer (AO), inter alia, noticed that the assessee is collecting inland haulage charges, from its customers, in respect of goods being transported from the places where containers are stuffed, inland container depots (ICD), to the port where these goods are to be loaded in the ships for i...