Computation of profits in case of non-resident shipping companies.

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....provisions relating to computation of profits in the case of non-resident shipping companies, Income-tax Officers are not allowing relief due to such companies under the relevant D.T.A. Agreements existing between India and other countries. 2. Our D.T.A Agreements with Federal Republic of Germany, Finland, France, Greece and Japan provide that the tax to be charged in India on the profits deriv....

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....Romania and Sweden, there is no such restriction even in the case of occasional shipping or tramp steamers. 3. Thus, it will be observed that in the case of the regular shipping lines belonging to the countries with which we have D.T.A. Agreements covering shipping profits, the reduction in tax by the specified percentage would be available even at the stage of ad-hoc assessment u/s 172(4) of t....