Case Law Analysis
|Income Tax Appellate Tribunal
Article 8 India-Germany DTAA | Income from Feeder Vessel Slot Arrangements Qualifies as Shipping Profits Exempt from Tax : ITAT Mumbai
The ITAT Mumbai has ruled that income earned by non-resident shipping companies from cargo transported via feeder vessels under slot arrangements constitutes shipping profits under Article 8 of the India-Germany DTAA, exempting it from Indian taxation under Section 44B. This clarifies that ancillary logistics supporting international shipping are integral to the core shipping activity, benefiting global liner operators using feeder networks to access shallow Indian ports.