Advance tax treatment of shipping voyage levy affirmed; regular assessment triggers interest liability and refund interest entitlement. Payment of the levy on each voyage by non-resident ship owners or charterers is to be treated as advance tax instalments; if the assessee opts for regular assessment under section 172(7) those payments are treated as tax paid in advance for that year. Administrative guidance denying interest consequences is withdrawn: regular assessment attracts standard interest liabilities for defaults and entitles the assessee to interest on any refund.
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Provisions expressly mentioned in the judgment/order text.
Advance tax treatment of shipping voyage levy affirmed; regular assessment triggers interest liability and refund interest entitlement.
Payment of the levy on each voyage by non-resident ship owners or charterers is to be treated as advance tax instalments; if the assessee opts for regular assessment under section 172(7) those payments are treated as tax paid in advance for that year. Administrative guidance denying interest consequences is withdrawn: regular assessment attracts standard interest liabilities for defaults and entitles the assessee to interest on any refund.
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