Ministry of Finance, through Notification No. 9/2025 dated January 21, 2025, introduced the Income-tax (First Amendment) Rules, 2025, effective from the date of its publication in the Official Gazette. This amendment inserts Rule 6GB into the Income-tax Rules, 1962, outlining special provisions under Section 44BBC for non-residents engaged in the business of operating cruise ships. To qualify, such ships must carry over 200 passengers or be at least 75 meters long, provide leisure and recreational services with dining and cabin facilities, operate on scheduled voyages or excursions touching at least two or the same Indian sea ports twice, primarily transport passengers rather than cargo, and adhere to procedures or guidelines issued by the Ministry of Tourism or Shipping. These provisions aim to standardize tax computation for non-resident cruise operators under specified conditions.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 9/2025- Income Tax| Dated: 21st January, 2025
G.S.R. 67(E).—In exercise of the powers conferred by section 295 read with the sub-section (1) of section 44BBC of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namely:___
1. (1) These rules may be called the Income-tax (First Amendment) Rules, 2025.
(2) They shall come into force on the date of their publication in the Official Gazette.
2. In the Income-tax Rules, 1962, after rule 6GA, the following shall be inserted, namely:–
“CCCB.__ Special provisions for computing profits and gains of business of operation of cruise ships in case of non-residents.
6GB. Conditions for non-resident, engaged in the business of operation of cruise ships for section 44BBC.– For the purposes of section 44BBC, an assessee, being a non-resident, engaged in the business of operation of cruise ships shall, __
i. operate a passenger ship having a carrying capacity of more than two hundred passengers or length of seventy-five meters or more, for leisure and recreational purposes and having appropriate dining and cabin facilities for passengers;
ii. operate such ship on scheduled voyage or shore excursion touching at least two sea ports of India or same sea ports of India twice;
iii. operate such ship primarily for carrying passengers and not for carrying cargo; and
iv. operate such ship as per the procedure and guidelines if any, issued by the Ministry of Tourism or Ministry of Shipping.”.
[Notification No. 9 /2025/ F.No.370142/18/2024-TPL]
SOURABH JAIN, Under Secy.
Note: The principal rules were published in the Gazette of India, Extraordinary, Part-II, section 3, sub-section (ii) vide number S.O. 969(E), dated the 26th March, 1962 and were last amended vide notification number G.S.R. 739(E) dated the 29th November, 2024.
