IT : Journey of a vessel between two Indian ports is "international traffic" under Art 8 of India-Singapore DTAA if the same is part of a larger journey between two foreign ports. It is only when a ship or aircraft is operating 'solely' between places in a contracting state that the transport is excluded from scope of "international traffic". It is not the case of the Revenue that the journey being undertaken by such vessels in question were confined between the two ports in India either routine
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