VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 44B: the 7.5 per cent shipping presumption, and why clause (i) and clause (ii) of sub-section (2) are not symmetrical
CBDT Circulars & InstructionsCuts both wayss.44Bs.44B(1)s.44B(2)s.172s.172(8)s.44BBs.44BB(3)s.44BBBs.44BBB(2)

Statutory position — section 44B: the 7.5 per cent shipping presumption, and why clause (i) and clause (ii) of sub-section (2) are not symmetrical

We are a foreign shipping line assessed under section 44B. The Assessing Officer has included freight we collected abroad and also our demurrage. What actually goes into the "aggregate of the amounts" under section 44B(2), and does it matter where the money was received?

We are a foreign shipping line assessed under section 44B. The Assessing Officer has included freight we collected abroad and also our demurrage. What actually goes into the "aggregate of the amounts" under section 44B(2), and does it matter where the money was received?

It matters, but only for cargo shipped at a port OUTSIDE India. Section 44B(2) has two clauses and they are deliberately different: clause (i) takes in the amount paid or payable "whether in or out of India" on account of carriage of passengers, livestock, mail or goods shipped at any port IN India, so where the freight was collected is irrelevant for an Indian loading; clause (ii) takes in only the amount "received or deemed to be received in India" on account of carriage of goods shipped at any port OUTSIDE India, so for a foreign loading receipt in India is the condition of charge. The Explanation to sub-section (2) then provides that the amount referred to in either clause shall include amounts by way of demurrage charges or handling charges or any other amount of similar nature.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1976-04-01, reported as Income-tax Act, 1961, s.44B, as printed on the departmental Year 2009 and Year 2000 pages. It bears on section 44B, section 44B(1), section 44B(2), section 172, section 172(8), section 44BB, section 44BB(3), section 44BBB, section 44BBB(2) of the Income Tax Act 1961, in Presumptive Taxation & Audit, Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. Two departmental editions, Year 2000 and Year 2009, print the section identically, which is the best evidence obtainable on this pass that the section is unchanged. That 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 later than Year 2009 exists. I carried out no check of judicial treatment of s.44B on this pass; this entry states the statutory text only.

Why it matters

Section 44B is the annual presumptive regime for a non-resident's shipping business and it overrides sections 28 to 43A. Three features decide assessments. First, the asymmetry just described is the whole of the answer to "is freight collected overseas taxable?" — for cargo lifted from an Indian port, yes, because clause (i) says "whether in or out of India"; for cargo lifted abroad, only if the money is received or deemed received in India. Reading clause (i)'s words into clause (ii), or the reverse, is the commonest error in this area. Second, the Explanation is a charging enlargement, not a clarification of accounting: demurrage and handling charges go into the 7.5 per cent base, and it was inserted by the Finance Act 1997 with retrospective effect from 1 April 1976 — the same instrument and the same retrospective date as the parallel s.172(8). Third, and this is the one that costs money: section 44B contains NO counterpart to s.44BB(3) or s.44BBB(2). A non-resident shipowner cannot escape the 7.5 per cent by producing audited books showing a lower profit or a loss. The presumption in s.44B is one-way. That is a sharp contrast with the mineral-oil and turnkey-power regimes and it should be priced into any decision about how a shipping business into India is structured. Note also what s.44B does NOT reach: it is confined to an assessee "engaged in the business of operation of ships", so a person who is not operating ships is outside it and falls to be taxed under the ordinary provisions.

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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