The assessee, a Hong Kong company engaged in operating ships in international traffic and offering its income to tax under section 44B in terms of article 8 of the India-Hong Kong DTAA, had 7.5 per cent. of its GST component added as deemed income under section 44B by the AO, confirmed by the DRP, and had book profit computed under section 115JB. On appeal, the Tribunal held that GST, being a statutory levy collected by the assessee in a fiduciary capacity on behalf of the Government and shown separately in invoices, carried no profit element and could not form part of the specified amounts contemplated under section 44B(2), consistent with its own earlier decisions holding service tax similarly excludable and with CBDT circulars clarifying that no tax need be deducted on separately indicated GST components, since section 44B, being a non obstante provision overriding sections 28 to 43A, was not governed by the inclusive valuation method under section 145A, and including GST in income would tantamount to taxing a tax, contrary to the legislative intent of taxing only charges recovered for shipping services; accordingly, the addition of GST was deleted. It further held that since the assessee had offered its income to tax under the deemed provisions of section 44B read with section 90(2), section 115JB was rendered inapplicable in view of Explanation 4A thereto, and book profit computed by the AO was to be deleted. (AY. 2020-21)