S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Business of operation of ships in international traffic-Treaty must be extended to entire freight receipts, irrespective of whether earnings are relating to feeder vessels or by ships in international traffic-DTAA-India-UAE. [S. 90, Art. 8]
Avana Global FZCO v. DCIT(IT) (2021) 191 ITD 627 (Mum.)(Trib.)