Profits from participation of cargo under ‘Slot Arrangement’ not eligible for benefit of Article 8 of India-Germany tax treaty

Hapag-Lloyod Container Line GMBH Vs. ADIT (ITAT Mumbai) 

Appeal No. ITA No. 8854/MUM/2010

Date of Judgment – 7 March 2012

Slot arrangement cannot be termed as pooling arrangement and in absence of owning, chartering or pooling of mother vessel, relief under the India-Germany tax treaty cannot be availed by a non resident.

ITAT held that profits from participation of cargo under

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