TaxTMI 
TaxTMI 
5106/1992.
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....dian ports to the intermediate ports can be allowed as a "deduction" in computing the income of the mother ships u/s. 172(2) of the Act. 4. There appears to have been a change in the pattern of shipping goods from and to Indian ports in the last few years when large bulk carriers are being employed by the International Shipping Companies who find it uneconomical to move the entire large ship to an Indian port to deliver or to take in a considerably small quantity of cargo. These large ships call on either at Singapore or at Colombo and smaller feeder ships operating between Singapore/Colombo and the Indian ports like Madras, carry the goods from such large ships to India or from India to such large ships calling at Singapore or Colombo. Th....
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....adras and Singapore/Colombo. 5. If the freight paid to the feeder ship is seen as a payment made or expenditure incurred by the mother ship, then as has been rightly pointed out in the assessment order in the case of M/s. Evergreen Marine Corporation enclosed to the petition, the income charged to tax u/s.172(2) of the Act is a deemed income, estimated at 7.5% of the freight charges received or receivable in India by the Non-resident ship owner. As the section stands today, there is no scope for allowing any deductions for any expenditure or outgoing from such an estimated income. Unless the Act is suitably amended, no such deduction can be made, since it has to be presumed that while prescribing the rate at 7.5%, the Government had taken ....