Where the assessee had earned freight income by transporting cargo in international traffic through ‘slot charter’ arrangements on ships owned by other enterprises and the question arose whether such profits arose from “operation of ships”, held: that in view of the OECD Commentary, Article 9 of the India-UK DTAA must be interpreted as applying not only to income arising directly from the operation of ships but also to income arising from ancillary operations such as transportation of cargo through ships owned by other enterprises.