Allowability of deduction u/s 33AC to the Assessee using ships/barges owned by the third party

RELEVANT PARAGRAPH 6. We have heard both the parties and perused the orders of the revenue authorities. The case of the revenue is that the ‘barges’ are not the ‘ships’ and the earnings made out of running and maintaining of the barges, which are not owned by the assessee, are not covered by the provisions of section 33AC of the Act. Further, the hiring receipts out of let out of assessee’s barge are also not eligible for deduction. Such incomes are not considered derived from the business of ‘operation of ships’. Considering the above issue, in our op...