DIRECTOR OF INCOME TAX (IT) - I vs A.P. MOLLER MAERSK A/S/

The Supreme Court addressed the classification of income from the use of the 'Maersk Net' system, determining it as integral to the shipping business rather than fees for technical services under Article 13(4) of the Indo-Danish Double Taxation Avoidance Agreement. The Court upheld the High Court's ruling that such income is not taxable in India, emphasizing the nature of the payments as reimbursements rather than service fees. Consequently, the appeals by the Revenue were dismissed, affirming the High Court's judgment.