The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 30 November 2005 (made public in January 2006) in the case of Assistant Director of Income Tax v. Green Emirate Shipping & Travels (99 TTJ 988 (Mumbai)) holding that a United Arab Emirates (UAE) entity was entitled to claim the benefits of India-UAE tax treaty of 29 April 1992 (the tax treaty) and therefore, it was not liable to tax in India on its income from shipping operations. (a) Facts. The taxpayer (i.e. Green Emirate Shipping & Travels) claimed that its income was liable to tax only in the...