The issue before the Tribunal was whether service tax collected by a non-resident airline and remitted to the Government formed part of the gross receipts for computing presumptive income under section 44BBA. The Tribunal held that service tax is collected by the assessee merely as an agent of the Government and does not contain any element of income. Since only amounts received for carriage of passengers, livestock or goods constitute gross receipts under section 44BBA, service tax could not be included for computing presumptive income. (AY. 2016-17 to 2018-19).