Held that freight income received on account of transportation of cargo on vessel under slot arrangement is eligible for benefit of exemption under article 8. (AY. 2017-18)
Hapag-Lloyd AG. v. DCIT (IT) (2022) 194 ITD 20 (Mum.)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Shipping inland waterways transport and air transport-Freight income received on account of transportation of cargo on vessel under slot arrangement basis is eligible for benefit of exemption to assessee under article 8 of DTAA between India and Germany. DTAA-India-Germany. [Art. 8]