https://www.taxtmi.com/caselaws?id=61907 Treaty relief under the India-Malta agreement could not be disallowed as a prima facie adjustment in summary processing under section 143(1)(a) because entitlement depended on a debatable effective-date issue and was not free from doubt. Section 172 was treated as a self-contained special code for non-resident shipping income, and a return filed under section 172(7) did not attract the general filing obligation under section 139(1). On that basis, interest under section 234A was held inapplicable to such a return. en-us Mon, 19 Apr 1999 00:00:00 +0530 Sat, 15 Jan 2011 19:04:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61907 Treaty relief under the India-Malta agreement could not be disallowed as a prima facie adjustment in summary processing under section 143(1)(a) because entitlement depended on a debatable effective-date issue and was not free from doubt. Section 172 was treated as a self-contained special code for non-resident shipping income, and a return filed under section 172(7) did not attract the general filing obligation under section 139(1). On that basis, interest under section 234A was held inapplicable to such a return. Case-Laws Income Tax Mon, 19 Apr 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61907