What is difference between Section 44B and section 172 of the Income Tax Act with respect to the business of Shipping Operation???


1.      While there is no specific distinction, it can be inferred that Section 44B is a special provision for computing profits and gains of an FSC engaged in 'regular' shipping business in India, while section 172 deals with taxation of an FSC engaged on "occasional" shipping business basis in India.

2.      One of the differences between the two sections is that section 44B does not prescribe any procedure to be followed for assessment and collection of tax. In other words, return filed u/s. 44B would be assessed under normal provisions of the Act. Further, the 'non obstante' clause refers only to sections 28 to 43A.


3.      On the other hand, section 172 prescribes a method for assessment and recovery of the tax, and the 'non obstante' clause refers to all other sections in the ITA.

4.      To avoid long drawn process of calculating profit, particularly in case of an FSC which includes apportionment of profit/allocation of proportionate expenses incurred worldwide, a sum equal to 7.5% of freight has been prescribed as deemed taxable income under presumptive taxation in both the sections. The only difference is the scope of income. Under section 44B,income has two limbs: First, the amount paid or payable to the assessee on account of carriage of passenger, livestock, mail or goods shipped at any port in India, and the second being the amount received or deemed to be received in India on account of above carriage, shipped at any port outside India. While under section 172, income definition covers only the first limb related to a particular ship.

5.      The return u/s. 44B needs to be filed annually irrespective of number of ships departing from the Indian port during the year. However, in case of section 172, ship wise return is required to be filed. The Master of a ship is responsible to prepare and file the Return of Income before the ship departs from the Indian port. Alternatively, it can be filed within the 30 days of departure of ships, if the master of ship has made arrangement for filing of Return of Income and payment of tax to the satisfaction of the AO. The assessment of the same needs to be completed within 9 months from the end of the financial year in which return is filed. U/s. 172, the owner or charterer of the ship has an option to get the income of the ship assessed under normal provisions of the Act. In this regard, declaration needs to be filed before the AO prior to the completion of the assessment year.

6.      In case where an FSC was not engaged in occasional shipping business, but in regular shipping business, and its Indian agent was regularly filing return of income and was assessed as well, it would be outside the scope of section 172; it would rather be liable to be assessed on basis of return filed under section 139(1) for its entire income (Rajkot ITAT in case of ITO (Int. Tax.) v. Marine Containers Services (India) (P.) Ltd. [2012] 28 taxmann.com 251/[2014] 61 SOT 260

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