https://www.taxtmi.com/caselaws?id=58091 The Tribunal held that the provisions of section 44B of the IT Act, deeming a flat rate of 7 1/2% of receipts as profits, supersede Circular No. 7(C) No. 27(17)-IT dated 10-2-1942 for non-resident shipping companies. The Tribunal emphasized that new statutory provisions impliedly withdraw old Circulars. Additionally, subsequent circulars from the Central Board of Direct Taxes provided updated guidelines, rendering the old Circular obsolete. The Tribunal upheld the imposition of penalties under section 221 despite subsequent tax payments, citing the retrospective effect of the declaratory Explanation and relevant legal precedents. en-us Fri, 10 Jul 1987 00:00:00 +0530 Fri, 17 Dec 2010 12:59:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58091 The Tribunal held that the provisions of section 44B of the IT Act, deeming a flat rate of 7 1/2% of receipts as profits, supersede Circular No. 7(C) No. 27(17)-IT dated 10-2-1942 for non-resident shipping companies. The Tribunal emphasized that new statutory provisions impliedly withdraw old Circulars. Additionally, subsequent circulars from the Central Board of Direct Taxes provided updated guidelines, rendering the old Circular obsolete. The Tribunal upheld the imposition of penalties under section 221 despite subsequent tax payments, citing the retrospective effect of the declaratory Explanation and relevant legal precedents. Case-Laws Income Tax Fri, 10 Jul 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58091