https://www.taxtmi.com/caselaws?id=16232 The court held that Section 44B of the Income-tax Act applies to the entire assessment year 1976-77, rejecting the assessees' argument to split the period. It clarified that the amendments to Section 172 should not be read together with Section 44B, emphasizing the distinct purposes of the two sections. The court highlighted that the Finance Act, 1975, clearly stipulated the effective dates of these provisions, and legislative intent must guide their interpretation. The court ruled in favor of the Revenue, emphasizing the separate application of Sections 44B and 172 for non-resident shipping companies. en-us Tue, 30 Sep 1997 00:00:00 +0530 Fri, 04 Sep 2009 16:20:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16232 The court held that Section 44B of the Income-tax Act applies to the entire assessment year 1976-77, rejecting the assessees' argument to split the period. It clarified that the amendments to Section 172 should not be read together with Section 44B, emphasizing the distinct purposes of the two sections. The court highlighted that the Finance Act, 1975, clearly stipulated the effective dates of these provisions, and legislative intent must guide their interpretation. The court ruled in favor of the Revenue, emphasizing the separate application of Sections 44B and 172 for non-resident shipping companies. Case-Laws Income Tax Tue, 30 Sep 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16232