Tribunal held that Para 4 of art. 21 of the Indo-Norway DTAA is applicable to the consideration received by the assessee for providing a vessel for transportation to entities engaged in the exploitation/exploration of seabed or subsoil and, therefore, its income is to be computed in terms of art. 21(4) of the DTAA; S. 44BB was not applicable(AY.2022-23)
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