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Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual ‘No Objection Certificate’, valid for a year, in respect of taxation of ship­ping profits under section 172, after carefully verifying ap­plicability of relevant provisions concerning taxation of ship­ping profits in double taxation agreement with country of which owner or charterer is resident - Income Tax - 732

Extract

..... n 172 of the Income-tax Act, 1961 seven and a half per cent of the amount paid or payable to the owner or charterer of a ship on account of carriage of pas­sengers, livestock, mail or goods shipped at a port in India, is deemed to be income accruing in India to the owner or the char­terer. The port clearance is granted only after the return of the full amount to be paid is filed, evidence of payment of tax on such income is produced before the Customs authorities, or satis­factory ar .....

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Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual ‘No Objection Certificate’, valid for a year, in respect of taxation of ship­ping profits under section 172, after carefully verifying ap­plicability of relevant provisions concerning taxation of ship­ping profits in double taxation agreement with country of which owner or charterer is resident - Income Tax

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..... ship­ping profits under section 172 of the Income-tax Act, 1961 after carefully verifying the applicability of the relevant provisions concerning taxation of shipping profits in the DTAA with the country of which the owner or the charterer is a resident. 5. While examining the relevant Articles of the DTAA, the Assess­ing Officer should ensure that the non-resident shipping company is engaged in ‘international traffic’, a term which is invariably defined in the DTAA itself. A .....

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Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual ‘No Objection Certificate’, valid for a year, in respect of taxation of ship­ping profits under section 172, after carefully verifying ap­plicability of relevant provisions concerning taxation of ship­ping profits in double taxation agreement with country of which owner or charterer is resident - Income Tax

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