In Brief
A shipping company with a Tonnage Tax Scheme (TTS) registration sought to include income from slot charter operations (hiring cargo space on vessels it did not own or fully charter) in its tonnage income calculation. The Revenue argued this income must be excluded since no qualifying ship certificate could be produced for partially chartered vessels. The Supreme Court upheld the High Court, holding that slot charter income qualifies as 'deemed tonnage' under the statutory scheme and does not require a certificate. The certificate requirement applies only to actual tonnage of owned or fully chartered ships, not to partial arrangements like slots. This interpretation recognizes the legislative intent to make Indian shipping competitive globally by permitting participation in slot charter—a standard global practice impossible to execute if each arrangement required identification of the specific vessel.
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