Use of facility does not amount to technical services

Freight income from operation of ships in international waters is not chargeable to tax under Indo-Danish DTAA; Use of facility does not amount to technical services, as technical services denote services catering to the special needs of the person using them and not a facility provided to all.

Pertinently, the Revenue itself has given the benefit of Indo-Danish DTAA to the assessee by accepting that under Article 9 thereof, freight income generated by the assessee in these Assessment Years is not chargeable

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