Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual ‘No Objection Certificate’, valid for a year, in respect of taxation of ship­ping profits under section 172, after carefully verifying ap­plicability of relevant provisions concerning taxation of ship­ping profits in double taxation agreement with country of which owner or charterer is resident

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..... sident
732 Dated:- 20-12-1995 Circular
Income Tax
Circular: No. 732 dated 20-12-1995. Whether in cases where no tax is payable in India, the Assessing Officer shall be competent to issue an annual 'No Objection Certificate', valid for a year, in respect of taxation of ship­ping profits under section 172, after carefully verifying ap­plicability of relevant provisions concerning .....

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..... rprise belonging to a country with which India has entered into an agreement on avoidance of double taxation, which provides for taxation of shipping profits only in the country of which the enterprise is a resident, no tax is payable by such ships at the Indian ports. Under such circumstances, a 'No Objection Certificate' is to be obtained by the master of the ship from the concerned income-tax a .....

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..... ident shipping company is engaged in 'international traffic', a term which is invariably defined in the DTAA itself. An undertaking from the non-resident company that during the period of the currency of the NOC, no ship belonging to it will be in any traffic other than 'interna­tional traffic', shall be obtained before the issue of the NOC.
Circular, Trade Notice, Public Notice, Instructi .....

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