NETHERLANDS STEAM NAVIGATION COMPANY LTD. vs THE COMMISSIONER OF INCOME-TAX, WEST BENGAL

The Supreme Court held that additional depreciation under Section 10(2)(vi-a) of the Income-tax Act, 1922 is not admissible for a non-resident shipping company when the computation of taxable income is based on a special formula rather than the second method in Rule 33. The Court clarified that while the second method would necessitate various depreciation allowances, the appellant could not claim additional depreciation when accepting a different method of profit determination. The High Court's ruling against the assessee was upheld, confirming the Income-tax Officer's assessment.