Treaty between India and United Kingdom – Indian decision that slot hire agreements fall within the ambit of operation of ships for treaty purposes

The High Court issued a decision on 6 August 2012 in the case of DIT v. Balaji Shipping UK Ltd. [TS-635-HC-2012 (Bom)] that slot hire agreements are integral to the operation of ships and therefore fall within the ambit of article 9 of the India - United Kingdom Income Tax Treaty (1993) (the Treaty).
(a) Facts. The Taxpayer (i.e. Balaji Shipping UK Ltd.) was a company incorporated in the United Kingdom (UK) and engaged in the international transportation of goods by se…