Assessee, a UAE-based company, was engaged in business of operating ships in international traffic. During the relevant year, assessee received an amount in the form of freight income and other related charges in India. Assessing Officer held that said incomes were earned from multiple ports in India involving hundreds of ship voyages with ships of different names and charterers. He thus denied the benefit of Article 8 of the India-UAE DTAA to assessee with respect to said income. DRP followed the directions of the assessment year 2017-18. On appeal, the Tribunal held that in assessee’s own case, Tribunal held that benefit of Article 8 was to be extended to entire freight receipts irrespective of whether earnings related to feeder vessels or by ships in international traffic. Since material facts remained the same, following decision of Tribunal in assessee’s own case for earlier years, the addition made by the Assessing Officer was deleted. Tribunal also held that income earned freight income, including inland haulage charges (IHC), since IHC were inextricably linked to the operation of ships in international traffic, could not be disintegrated from the profit derived from the shipping business as envisaged under Article 8 of the India-UAE DTAA and was not taxable as business profit in India. (AY. 2022-23)