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Treatment of tax paid under section 172(3) by non-resident engaged in shipping business - Clarification Regarding.

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..... 961, deals with shipping business of non-residents. The scheme of section 172 is that every time a ship belonging to or chartered by a non-resident makes a voyage from a port in India, carrying passengers, live-stock, mail or goods, shipped at the airport, 7 1/2 per cent, of the amount paid or payable on account of the carriage of the passengers etc. is taken as the income and tax levied on such i .....

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..... ) by the non-resident owner or charterer would be treated as a payment in advance of the tax leviable for that assessment year before determining the amount of tax finally due. It may be noted that under section 172(7), the choice is entirely that of the non-resident taxpayer to be assessed under the other provisions of the Act. 4. The payment made under section 172(4) by a non-resident ship ow .....

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..... e nature referred to in sub-section (2) of section 172 of the I.T. Act, 1961. 6. Hence, the Board is of the opinion that non-resident assessees engaged in the business of carriage by shipping of passengers and goods, etc. shall neither be liable to pay interest under sections 234B and 234C nor entitled to interest under section 244A of the I.T Act, 1961 in respect of their income attributable o .....

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