Inland Haulage Charges received by Shipping Companies not Taxable as Business Profit

Avana Global FZCO Vs DCIT (ITAT Mumbai)

Article – 8 of India-UAE DTAA deals with profits derived by operation of ships in international traffic. Clause 2(b) of Article-8 refers to profit from the rental of ship including operation of container and related equipment used in connection with operation of ships in international traffic. Though Article-8 of India -UAE DTAA does not spell out explicitly that rental of containers include trailers and related equipment for the transport of container as has been mentioned in India -Belgium DTAA Article 8(2)(c)

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