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The ITAT allowed the taxpayer's appeal, deleting the Assessing Officer's addition and holding that income from international shipping operations, including freight and ancillary charges arising from voyages involving Indian ports, is not taxable in India under section 44B. The Tribunal found that the receipts derived from carriage of goods by sea do not constitute income attributable to a place of business in India for the purposes of the provision, and accordingly sustained the taxpayer's grounds on merits. The re-assessment of such shipping income in the hands of the taxpayer was set aside, with the addition deleted and relief granted in favor of the taxpayer.
The ITAT allowed the taxpayer's appeal, deleting the Assessing Officer's addition and holding that income from international shipping operations, including freight and ancillary charges arising from voyages involving Indian ports, is not taxable in India under section 44B. The Tribunal found that the receipts derived from carriage of goods by sea do not constitute income attributable to a place of business in India for the purposes of the provision, and accordingly sustained the taxpayer's grounds on merits. The re-assessment of such shipping income in the hands of the taxpayer was set aside, with the addition deleted and relief granted in favor of the taxpayer.
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