https://www.taxtmi.com/circulars?id=10403 Deemed income under section 172 is chargeable on the entire freight where the bill of lading shows the mothership as recipient; payments to a daughter vessel operator are treated as expenditure implicitly covered when estimating deemed income at the prescribed rate, and the daughter operator is separately taxable on its own freight receipts. Administrative apportionment relief would require a Board clarificatory circular; absent that and absent agreements or separate exporter payments, apportionment is not recommended. en-us Fri, 16 Jul 1993 00:00:00 +0530 Mon, 13 Jun 2011 18:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=10403 Deemed income under section 172 is chargeable on the entire freight where the bill of lading shows the mothership as recipient; payments to a daughter vessel operator are treated as expenditure implicitly covered when estimating deemed income at the prescribed rate, and the daughter operator is separately taxable on its own freight receipts. Administrative apportionment relief would require a Board clarificatory circular; absent that and absent agreements or separate exporter payments, apportionment is not recommended. Circulars Income Tax Fri, 16 Jul 1993 00:00:00 +0530 https://www.taxtmi.com/circulars?id=10403