ITAT explains taxability of Amount received for Time Charter of ship

Nan Lian Ship Management LLC Vs ACIT (Int. Tax) (ITAT Mumbai) The aforesaid appeal has been filed by the assessee against the final assessment order dated 27.05.2022, passed by Ld. AO u/s 143(3) r.w.s. 144C(13) for the AY 2019-20 in pursuance of direction given by Ld. DRP vide order dated 18.05.2022 u/s 144C(5). 2. In the grounds of appeal, assessee has challenged the direction of Ld. DRP in treating the amount of Rs. 20,28,98,639/-received by the assessee on account of Time Charter of its ship as „royalty‟ and taxing the same u/s 9(1)(vi) of the Act. 3. The facts in brief are that, assess...