Special provision for computing profits and gains of business of operation of cruise ships in case of non-residents - Section 44BBC - International Taxation - Income Tax

Section 44BBC - Special provision for computing profits and gains of business of operation of cruise ships in case of non-residents [ w.e.f. 01.04.2025 Inserted vide Finance (No. 2) Act, 2024 ] Applicability In the case of an assessee, being a non-resident, engaged in the business of operation of cruise ships subject to such conditions as may be prescribed, Chargeable under head Income form such business chargeable to tax under the head Profits and gains of business or profession. Deemed Profit Taxable A sum equal to 20% of the aggregate of the amounts of (a) the amount paid or payable to the assessee or to any person on his behalf on account of the carriage of passengers; and (b) the amount received or deemed to be received by or on behalf of the assessee on account of the carriage of passengers. Without any deduction of expenditure contained in sections 28 to 43A. Exemption available for next 5 year Incomes not included in total income [ Section 10(15B) w.e.f. 01.04.2025 inserted vide Finance (No.2) Act, 2024 ] Any income of a foreign company from lease rentals, by whatever name called, of cruise ships, received from a specified company which operates such ship or ships in India, where such foreign company and the specified company are subsidiaries of the same holding company, and such income is received or accrues or arises in India for any relevant assessment year beginning on or before the 1st day of April, 2030. For the purposes of this clause, - (a) specified company means any company, other than a domestic company which operates cruise ships in India and opts to pay tax in accordance with the provisions of section 44BBC; (b) holding company , in relation to a foreign company or a specified company, means a company of which such companies are subsidiary companies; (c) subsidiary company or subsidiary , in relation to a holding company, means a company in which the holding company exercises or controls more than one-half of the total share capital either at its own or together with one or more of its subsidiary companies