Ship Time Charter Income Taxed as "Royalty" Under IT Act Section 9(1)(vi) and Section 44B for Shipping Ops.

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....Income deemed to accrue or arise in India - amount received by the assessee on account of Time Charter of its ship as “royalty‟ and taxing the same u/s 9(1)(vi) - the payment received by the owner from the charterer has to be reckoned as payment from operations of carriage of goods from one port in India to another port in India, which falls under the ambit of carrying out shipping business or shipping operators. - the income of the assessee has rightly been offered to tax u/s 44B - AT....