Held that\u00a0\u00a0 that J had issued a certificate specifically confirming the fact that it had considered the income\u00a0 on accrual basis earned on the vessel in question during its voyage from September 28, 2016 to October 27, 2016 while it was in international traffic and passed through Indian waters and accordingly the assessee had offered its taxes to the Singapore Revenue authorities. The certificate of the Singapore Revenue authorities issued on December 10, 2016 clearly mentioned that the assessee had discharged estimated tax as per the original assessment dated March 29, 2016. The\u00a0Double Taxation Avoidance Agreement between India and Singapore\u00a0was applicable as the assessee had already paid taxes for the international voyage of vessel MV for the period September 28, 2016 to October 27, 2016 while it was in international traffic, which included the voyage from one Indian port to another Indian port. The stand of the Revenue that the assessee had not paid the taxes in Singapore was incorrect, and in fact, it was not just a coastal run but a part of an international voyage. Therefore, articlesandof\u00a0Double Taxation Avoidance Agreement between India and Singapore\u00a0were applicable.(AY.2017-18)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 172 : Shipping business-Non-residents-Vessel journeying between Indian ports \u2014Journey was a part of International voyage \u2014Not taxable in India-DTAA-India-Singapore.[S.172(4), art. 8, 24] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-45321","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-bMZ","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45321","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=45321"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45321\/revisions"}],"predecessor-version":[{"id":45322,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45321\/revisions\/45322"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=45321"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=45321"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=45321"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}