https://www.taxtmi.com/caselaws?id=218799 Section 172(4) could not be applied where the non-resident shipping activity was not merely occasional and the assessee was already filing returns under section 139(1) and being assessed under section 44B. On those facts, the matter fell within the regular assessment framework, and the Tribunal accepted that section 172(4) was not sustainable. It also noted that the Assessing Officer could examine the position and, if warranted, proceed under section 172(7) so that income from the voyages was brought to tax under the normal provisions. en-us Fri, 19 Oct 2012 00:00:00 +0530 Mon, 26 Nov 2012 08:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218799 Section 172(4) could not be applied where the non-resident shipping activity was not merely occasional and the assessee was already filing returns under section 139(1) and being assessed under section 44B. On those facts, the matter fell within the regular assessment framework, and the Tribunal accepted that section 172(4) was not sustainable. It also noted that the Assessing Officer could examine the position and, if warranted, proceed under section 172(7) so that income from the voyages was brought to tax under the normal provisions. Case-Laws Income Tax Fri, 19 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218799