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The Shipping Corporation Of India Ltd, ... vs Dcit (Ltu), Mumbai on 2 November, 2018

9. In view of the above facts and legal position, we are of the considered opinion that the issue requires factual verification to ascertain whether the fixed deposits were placed for obtaining banking facilities required for carrying on the shipping business of the assessee or whether the same were independent investments. Accordingly, we restore this issue to the file of the Assessing Officer with a direction to examine the nature and purpose of the fixed deposits in the light of the decision of the Tribunal in the case of Shipping Corporation of India (supra) and other judicial precedents. The Assessing Officer shall also consider the assessee's submission regarding interest of ₹65,701/- relating to FDs not linked with overdraft facility. Needless to say, the Assessing Officer shall afford adequate opportunity of being heard to the assessee before deciding the issue.
Income Tax Appellate Tribunal - Mumbai Cites 56 - Cited by 4 - Full Document

Tolani Shipping Co. Ltd., Mumbai vs Dcit,Cir-5(3)(2), Mumbai on 30 March, 2021

8. We further note that the assessee itself in its submission before the Assessing Officer dated 10.12.2019 had stated that interest income of ₹65,701/- relates to fixed deposits which were not kept against any overdraft facility and that the same may be taxed under the head Income from Other Sources. However, the Assessing Officer has not 3 ITA No.4659/M/2025 Galleon Shipping Limited examined the said submission while completing the assessment. The tribunal in the case of Pratibha Shipping Co. Ltd. (supra) holds that where the fixed deposits are not connected with the shipping activity, the interest income cannot be treated as shipping income under the tonnage tax scheme.
Income Tax Appellate Tribunal - Mumbai Cites 52 - Cited by 1 - Full Document
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