Section 225 is the substantive equivalent of 1961 s. 115 V (Tonnage Tax framework anchor). The TONNAGE TAX SCHEME is an alternative tax regime for qualifying SHIPPING COMPANIES, where income from operating qualifying ships is computed on…
225
ITA 2025 · Section 225
Section 225 — - TONNAGE TAX REGIME CHARGE
Section 225 is the substantive equivalent of 1961 s. 115V (Tonnage Tax framework anchor). The TONNAGE TAX SCHEME is an alternative tax regime for qualifying SHIPPING COMPANIES, where income from operating qualifying ships is computed on TONNAGE BASIS (notional income per ton per day) rather than under regular PGBP rules. Adopted from international practice (UK / Netherlands / Greece / Singapore tonnage tax regimes). Optional regime; once opted, binding for 10 years. Section 225 establishes the charge: irrespective of ss. 26-54 (regular PGBP rules, except ss. 50 and 53), tonnage income from qualifying ship operations is computed per Tonnage Tax Part of Chapter XIII (ss. 226-235).
STATUTORY ARCHITECTURE: Tonnage Tax = ALTERNATIVE TAX REGIME for shipping companies based on NOTIONAL TONNAGE INCOME rather than actual profit. Section 225 makes the charge: irrespective of regular PGBP provisions (ss. 26-54), TONNAGE INCOME is computed for qualifying-ship operations. SS. 50 and 53 carve-outs preserve specific provisions (depreciation methodology) even under tonnage regime. POLICY RATIONALE: shipping is highly cyclical; tonnage tax provides stable predictable tax base; aligns Indian shipping tax with international competitive jurisdictions. OPERATIONAL FRAMEWORK (ss. 226-235): - s. 226: Qualifying company definition; - s. 227: Tonnage income computation methodology; - s. 228: Relevant shipping income; - s. 229: Depreciation under tonnage tax; - s. 230-231: Option exercise / 10-year binding; - s. 232: Conditions of operation; - s. 233-234: Withdrawal / cessation; - s. 235: Definitions.
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