Held that the assessee has offered income of operation of ships to tax under the deeming provisions of s. 44B r/w s. 90(2) and art. 8 of India-Hong Kong Tax Treaty; and therefore, in view of Expln. 4A to s. 115JB(1), the provisions of S. 115JB are not applicable to the assessee. (AY. 2020-21)
Orient Overseas Container Line Ltd. v. Dy.CIT (IT) [2024] 168 taxmann.com 269 / (2025) 233 TTJ 83 (Mum)(Trib)
115JB : Company-Book profit-Income from operation of ships-Income offered income under deeming provision-Provsion of book profit is not applicable-DTAA-India Hing Kong. [S. 44B, 90(2), Art. 8]
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