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Case lawCBDT Circulars & Instructions › Statutory position — section 44BBA: the 5 per cent presumption for a non-resident operating aircraft, and the lower-profit option it does not contain
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Statutory position — section 44BBA: the 5 per cent presumption for a non-resident operating aircraft, and the lower-profit option it does not contain

Our foreign airline made a loss on its India operations and our books are audited. The Assessing Officer says 5 per cent of our gross collections is taxable under section 44BBA regardless. Is there any provision letting us claim the lower figure?

Our foreign airline made a loss on its India operations and our books are audited. The Assessing Officer says 5 per cent of our gross collections is taxable under section 44BBA regardless. Is there any provision letting us claim the lower figure?

Not in section 44BBA itself. Section 44BBA(1) deems 5 per cent of the aggregate of the sub-section (2) amounts to be the profits of a non-resident engaged in the business of operation of aircraft, notwithstanding sections 28 to 43A, and the section as printed contains only two sub-sections: there is no counterpart to s.44BB(3) or s.44BBB(2), which is what lets a mineral-oil contractor or a turnkey power contractor claim lower profits on audited books. Sub-section (2) takes in (a) the amount paid or payable, whether in or out of India, on account of carriage of passengers, livestock, mail or goods FROM any place in India, and (b) the amount received or deemed to be received in India on account of such carriage FROM any place outside India.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1988-04-01, reported as Income-tax Act, 1961, s.44BBA, as printed on the departmental Year 2009 and Year 2000 pages; inserted by the Finance Act, 1987 with effect from 1 April 1988 per the footnote on those pages. It bears on section 44BBA, section 44BBA(1), section 44BBA(2), section 44B, 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 and neither carries any amending-Act footnote beyond the insertion by the Finance Act 1987. That is the best evidence obtainable on this pass that the section is unchanged. 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.44BBA on this pass.

Why it matters

Three points repay attention. First, the missing lower-profit option is the whole commercial significance of this section: a non-resident airline that is loss-making on its Indian traffic has no statutory route inside s.44BBA to displace the 5 per cent, and the argument has to be pitched either on the section not applying at all — the assessee is not "engaged in the business of operation of aircraft" — or on a treaty. The library already holds Caribjet Inc. v. DCIT on the first of those, holding that a wet lease is not operation of aircraft. Second, the connecting factor is different from the shipping sections and the difference is in the words: s.44B and s.172 speak of goods "shipped at a port in India", whereas s.44BBA speaks of carriage "from any place in India". "Place", not "port" — the aircraft section is not confined to gateway airports in the way a literal reading of the shipping sections might suggest. Third, the asymmetry between clause (a) and clause (b) is the same as in s.44B: for carriage from India the amount is taken whether paid in or out of India; for carriage from outside India only what is received or deemed received in India is taken. The percentage differs from the shipping figure — five per cent, not seven and a half — and the clauses are lettered (a) and (b) here where s.44B letters them (i) and (ii); do not carry a citation across from one section to the other.

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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