Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual No Objection Certificate (NOC), valid for a year, in respect of taxation of shipping profits under section 172, after carefully verifying applicability of relevant provisions concerning taxation of shipping profits in double taxation agreement with country of which owner or charterer is resident
Circular: No. 732, dated 20-12-1995.
1. Under the provisions of section 172 of the Income-tax Act, 1961 seven and a half per cent of the amount paid or payable to the owner or charterer of a ship on account of carriage of passengers, livestock, mail or goods shipped at a port in India, is deemed to be income accruing in India to the owner or the charterer. The port clearance is granted only after the return of the full amount to be paid is filed,