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Case lawCBDT Circulars & Instructions › Statutory position — section 172: the 7.5 per cent freight levy on a non-resident's ship, the master's return, the nine-month limit in s.172(4A), and the owner's election under s.172(7)
CBDT Circulars & InstructionsCuts both wayss.172s.172(1)s.172(2)s.172(3)s.172(4)s.172(4A)s.172(5)s.172(6)s.172(7)s.172(8)s.44Bs.194s.195

Statutory position — section 172: the 7.5 per cent freight levy on a non-resident's ship, the master's return, the nine-month limit in s.172(4A), and the owner's election under s.172(7)

A foreign ship loaded our cargo at an Indian port and the Assessing Officer is demanding tax from the master before port clearance. What is the levy, what return has to be filed, is there any time limit on the officer, and can the owner ask instead to be assessed on his year's income?

A foreign ship loaded our cargo at an Indian port and the Assessing Officer is demanding tax from the master before port clearance. What is the levy, what return has to be filed, is there any time limit on the officer, and can the owner ask instead to be assessed on his year's income?

Section 172 is a self-contained levy that operates voyage by voyage: where a ship belonging to or chartered by a non-resident carries passengers, livestock, mail or goods shipped at a port in India, s.172(2) deems 7.5 per cent of the amount paid or payable for that carriage — whether paid in or out of India — to be income accruing in India, and s.172(4) makes the tax payable by the master of the ship at the rate applicable to a company that has not made the arrangements referred to in s.194. The master must furnish a return under s.172(3) before the ship's departure, though the officer may accept a return filed within thirty days of departure by an authorised person where satisfactory arrangements have been made; s.172(6) withholds port clearance until the tax is paid or arrangements made; s.172(4A) bars any assessment order under s.172(4) after nine months from the end of the financial year in which the s.172(3) return is furnished; and s.172(7) lets the owner or charterer claim, before the expiry of the assessment year relevant to the previous year in which the date of departure falls, that an assessment be made of his total income under the other provisions of the Act, in which case the s.172 payments are treated as a payment in advance of the tax.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2007-04-01, reported as Income-tax Act, 1961, s.172, as printed on the departmental Year 2010 page and reproduced in extenso at para 29 of CIT v. V.S. Dempo & Co. Pvt. Ltd. (Bombay High Court, Full Bench, 5 February 2016). It bears on section 172, section 172(1), section 172(2), section 172(3), section 172(4), section 172(4A), section 172(5), section 172(6), section 172(7), section 172(8), section 44B, section 194, section 195 of the Income Tax Act 1961, in Presumptive Taxation & Audit, Assessment & Scrutiny and Demand, Recovery & Stay matters.

Still good law. Two departmental editions (Year 2009 and Year 2010) print the section identically, and the Bombay High Court reproduced the same text, sub-section (4A) included, in a judgment delivered on 5 February 2016. That is the best evidence obtainable on this pass that the section is unchanged as it stood for the years the Income-tax Act, 1961 governs. It is not the same as reading the current Finance Act: no Finance Act text was retrieved this pass, and I could not establish whether a departmental edition of s.172 later than Year 2010 exists. I carried out no check of judicial treatment of the section as a whole.

Why it matters

Five things in this section decide real money and are routinely missed. First, the base: s.172(8) expressly draws demurrage charge, handling charge "or any other amount of similar nature" into the amount on which the 7.5 per cent is computed, so a ship-owner who thinks only ocean freight is caught is wrong — that sub-section was inserted by the Finance Act 1997 with retrospective effect from 1 April 1976. Second, the words "whether that amount is paid or payable in or out of India" in s.172(2) mean the levy does not turn on where the freight is collected. Third, s.172(4A) is a limitation provision and it is the ground that wins a stale s.172 assessment outright: no order under s.172(4) may be made after nine months from the end of the financial year in which the s.172(3) return was furnished. It was inserted by the Finance Act 2007 with effect from 1 April 2007 and it does not appear at all on the older departmental editions of this section, which is why it is so often overlooked. Fourth, the s.172(7) election is a right of the owner or charterer, not of the master or the agent, and it is time-barred: it must be claimed before the expiry of the assessment year relevant to the previous year in which the date of departure from the Indian port falls. Fifth, the section carries a non-obstante clause in sub-section (1) — it applies "notwithstanding anything contained in the other provisions of this Act" — and that clause is the foundation of both the CBDT's position that ss.194C and 195 do not apply to payments covered by s.172 and of the Bombay High Court Full Bench's reading of s.172 alongside s.44B. Note finally where the section sits: the Supreme Court in A.S. Glittre recorded at para 4 that s.172 occurs in Chapter XV, Liability in Special Cases, under the sub-heading "Profits of non-residents from occasional shipping business", while the marginal heading of the section itself is "Shipping business of non-residents". The word "occasional" in the Chapter sub-heading is what distinguishes this summary voyage levy from the annual presumptive regime in s.44B.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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