Taxability of Income of a non-resident shipping company can in India

RELEVANT PARAGRAPH 4. We have given our anxious considerations to the rival submissions of the parties. We have also carefully considered the facts which are placed before us. In our opinion, the controversy is in a very narrow compass. There is no dispute about the fact so far as M/s. SCML is concerned, it is a foreign company which is operating the Cruises in the international waters. The said company has entered into the agreement with the assessee company and as per the terms of the agreement, the assessee has to canvass the sale of the Cruise tickets in India and the sale proceeds collect...