Commissioner Of Income Tax, Kochi vs Trans Asian Shipping Services (P) Ltd

The Supreme Court clarified the provisions of Chapter XIIG of the Income Tax Act, 1961, specifically Section 115VA, which allows shipping companies to opt for a special method of income computation for operating qualifying ships, overriding the general provisions in Sections 28 to 43C. The Court held that once the option is exercised, the income is deemed to be profits and gains chargeable to tax under the head 'Profits and Gains of Business or Profession'. The judgment emphasizes that only income from the business of operating qualifying ships can be computed under these special provisions, while income from other businesses must follow the standard computation methods.