Payment under section 172 treated as tax on voyage receipts, not advance tax, so no interest under sections 234B/234C. Tax on voyage receipts under section 172 is payable before port clearance; a non-resident may elect assessment on total income under general provisions, and tax paid under section 172(4) is treated as payment toward that assessment but is not treated as advance tax. Therefore, such taxpayers are not liable for advance-tax interest provisions nor entitled to refund interest for income solely from carriage by shipping.
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Provisions expressly mentioned in the judgment/order text.
Payment under section 172 treated as tax on voyage receipts, not advance tax, so no interest under sections 234B/234C.
Tax on voyage receipts under section 172 is payable before port clearance; a non-resident may elect assessment on total income under general provisions, and tax paid under section 172(4) is treated as payment toward that assessment but is not treated as advance tax. Therefore, such taxpayers are not liable for advance-tax interest provisions nor entitled to refund interest for income solely from carriage by shipping.
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