https://www.taxtmi.com/circulars?id=9969 Under section 172 the deemed income of non resident shipowners is assessed at a prescribed rate on freight received in India and contains no provision for deducting payments to feeder ships; therefore such payments cannot be allowed as deductions absent legislative change. Alternatively, treating the issue as one of apportionment yields that each vessel should be taxed only on the portion of freight it actually earns for its segment, and the Board may direct Assessing Officers to levy tax accordingly to avoid double taxation. en-us Tue, 17 Nov 1992 00:00:00 +0530 Thu, 09 Jun 2011 18:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=9969 Under section 172 the deemed income of non resident shipowners is assessed at a prescribed rate on freight received in India and contains no provision for deducting payments to feeder ships; therefore such payments cannot be allowed as deductions absent legislative change. Alternatively, treating the issue as one of apportionment yields that each vessel should be taxed only on the portion of freight it actually earns for its segment, and the Board may direct Assessing Officers to levy tax accordingly to avoid double taxation. Circulars Income Tax Tue, 17 Nov 1992 00:00:00 +0530 https://www.taxtmi.com/circulars?id=9969