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TMI Blog2016 (7) TMI 1377X X X X Extracts X X X X X X X X Extracts X X X X ..... 681 - BOMBAY HIGH COURT) held that the benefits of the DTAA between India and Germany would be available to the assessee even in respect of revenues earned from Feeder vessels obtained by the assessee by slot hire arrangements. - Decided against revenue - ITA No. 1624/MUM/2015, ITA No. 1625/MUM/2015, ITA No. 1626/MUM/2015, ITA No. 1627/MUM/2015, ITA No. 1628/MUM/2015 - - - Dated:- 22-7-2016 - SHRI G.S.PANNU, ACCOUNTANT MEMBER AND SHRI AMARJIT SINGH, JUDICIAL MEMBER Appellant by : Shri Jasbir S. Chouhan Respondent by : Shri Nishant Thakkar ORDER PER G.S.PANNU,A.M: The captioned five appeals by the Revenue are directed against a common order of the DRP-1 pertaining to assessment years 2006-07, 2008-09, 2009-10, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... um partners do not come to the Indian Ports. In such situations, assessee company engages feeder vessels to transport cargo from the originating port to the hub port (i.e. the intermediary port where vessels owned/chartered/pooled by assessee- company are anchored). From the hub to the destination port, the cargo is transported on vessels owned/chartered/pooled by the assessee- company. In the course of such business operations, assessee- company transports cargo on slot arrangements from origin port to the destination port. 3.1 In the return of income filed for assessment year 2006-07, the assessee-company claimed that the entire income in India comprised of profits derived from operation of ships in international traffic and such inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... venue before us, are based on the order of the Tribunal dated 14/08/2013(supra) in the assessee s own case for assessment year 2007-08, which continues to subsist. As a consequence, we find no reason to interfere in the directions made by the DRP. The only plea of the Revenue, as manifested in the above stated Ground of appeal, is that an appeal has been preferred in the High Court against the order of the Tribunal for assessment year 2007- 08. So however, mere filing of an appeal does not distract from the fact that the order of the Tribunal dated 14/08/2013 (supra) continues to hold the field inasmuch as the same has not been altered by any higher authority. As a consequence, we find no merit in the appeal of the Revenue, which is hereby ..... X X X X Extracts X X X X X X X X Extracts X X X X
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