Income chargeable to tax u/s 172.

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....etter and re-examined the issue. 2. In my predecessor's report dt. 17-11-92, it was stated that income charged to tax u/s.172 of the I.T. Act is a deemed income and there is no scope for allowing any deduction for any expenditure or outgoings since the presumption is that while estimating the income at the prescribed rate of 7.5%, the expenditure and outgoings by the non-resident Shipping compa....

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....osing a copy of the letter addressed by the Andhra Chamber of Commerce addressed to the ITO, Company Ward-I(4), Madras. The letter makes it clear that there are no agreements between the exporters and the mother vessel operators. It is vaguely suggested that it is the local shipping agent who books the cargo and collects the freight. From this, no inference can be drawn regarding the determination....

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....t the mother shipper is actually the recipient for the entire freight earnings as per the Bill of lading. Instead of directly incurring the expenditure by operating its own ship, the mother ship operator incurs expenditure through payment to the daughter vessel operator, the mother ship operator is spared of incurring the expenditure for taking the cargo from the Indian ports to Singapore/Colombo.....