CBDT Prescribes Conditions for NRs Engaged in Business of Operation of Cruise Ships for Sec. 44BBC

Notification No. 9 /2025, dated 21-01-2025

The Finance (No. 2) Act, 2024 inserted a new Section 44BBC in the Income-tax Act, 1961, relating to a special provision for computing the profits and gains of the business of operating cruise ships in the case of non-residents.

Section 44BBC provides that a sum equal to 20% of the aggregate of the specified amounts shall be deemed to be the profits and gains of business chargeable to tax under the head “Profits and gains of business or profession” in the case of a non-resident assessee subject to such conditions as may be prescribed.

To prescribe such conditions, the Central Board of Direct Taxes (CBDT) has issued a notification inserting a new rule 6GB to the Income-tax Rules 1962.

Rule 6GB provides the following conditions to be fulfilled by non-residents engaged in the business of operation of cruise ships and opting for a presumptive taxation scheme under section 44BBC:

a) Operate a passenger ship having a carrying capacity of more than two hundred passengers or a length of seventy-five meters or more for leisure and recreational purposes and having appropriate dining and cabin facilities for passengers;

b) operate such ship on scheduled voyages or shore excursions touching at least two sea ports of India or the same sea ports of India twice;

c) operate such ship primarily for carrying passengers and not for carrying cargo and

d) operate such ship as per the procedure and guidelines if any, issued by the Ministry of Tourism or Ministry of Shipping.

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