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100% DIT relief to France resident shipping company

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(Querist)
19 May 2022 M/s.CMA CGM of France has been granted 100% DIT relief on Imcome earned in operation vessel 23 vessel in the internation traffic. However, if the vessel carrying the cargo is not in the list of 23 vessel for which DIT is granted, is the DIT relief applicable or can I deduct the tax.
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CA R SEETHARAMAN

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CA R SEETHARAMAN (Expert)
20 May 2022 TDS not applicable on foreign vessels.
In view of under Section 44B of Income Tax Act, 1961; Income of a Foreign Shipping Business in India shall be presumed to be 7.5% of the income and the tax shall be such as applicable to a Non-resident.
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