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 sea. The vessels chartered by the Taxpayer did not ply within Indian territorial waters. Therefore, the Taxpayer entered into slot hire agreements with...