Deemed income under section 172: mothership taxed on whole freight; daughter vessel payments treated as deemed expenditure. Deemed income under section 172 is chargeable on the entire freight where the bill of lading shows the mothership as recipient; payments to a daughter vessel operator are treated as expenditure implicitly covered when estimating deemed income at the prescribed rate, and the daughter operator is separately taxable on its own freight receipts. Administrative apportionment relief would require a Board clarificatory circular; absent that and absent agreements or separate exporter payments, apportionment is not recommended.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed income under section 172: mothership taxed on whole freight; daughter vessel payments treated as deemed expenditure.
Deemed income under section 172 is chargeable on the entire freight where the bill of lading shows the mothership as recipient; payments to a daughter vessel operator are treated as expenditure implicitly covered when estimating deemed income at the prescribed rate, and the daughter operator is separately taxable on its own freight receipts. Administrative apportionment relief would require a Board clarificatory circular; absent that and absent agreements or separate exporter payments, apportionment is not recommended.
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