‘Freight beneficiary’ in a shipping business to be assessed under normal Income tax provisions and not u/s. 172

Learn about a legal ruling on tax assessment for a freight company engaged in regular shipping business. Details on jurisdiction and DTAA implications. Looking to the magnitude of the voyages undertaken by the freight beneficiary and the fact that the respondent-company has been, as observed by the ld. CIT(A), regularly filing its return of income at Mumbai and being assessed to tax at Mumbai, the finding of the CIT(A) that the freight beneficiary is not engaged in occasional shipping business but in regular shipping business and hence would be outside the scope of section 172 cannot be said t...