Income Tax Act, 2025  ·  Chapter XII — Tax on Special Incomes  ·  Section 226

Section 226
Tonnage tax scheme

IT Act 2025 Chapter XII Effective 1 April 2026 Old: 115VB
New Provision
Section 226, IT Act 2025
Replaces (IT Act 1961)
115VB
Chapter
Chapter XII — Tax on Special Incomes
Effective From
1 April 2026
Statutory Text — Section 226

(1) In this Part, a company shall— (a) be regarded as operating a ship or inland vessel, as the case may be, if it operates any ship or inland vessel, as the case may be, whether owned or chartered by it and includes a case where even a part of the ship or inland vessel, as the case may be, has been chartered in by it in an arrangement such as slot charter, space charter or joint charter; (b) not be regarded as operating a ship or inland vessel, as the case may be, which has been chartered out by it on bareboat charter-cum- demise terms or on bareboat charter terms for a period exceeding three years. (2) A tonnage tax company engaged in the business of operating qualifying ships shall compute the profits from such business under the tonnage tax scheme. (3) The tonnage tax business shall be considered as a separate business distinct from all other activities or business carried on by the company. (4) The profits referred to in sub-section (2) shall be computed separately from the profits and gains from any other business. (5) The tonnage tax scheme shall apply only if an option to that effect is made as per section 231. (6) Where a company engaged in the business of operating qualifying ships,–– (a) is not covered under the tonnage tax scheme; or (b) has not made an option in respect of the tonnage tax scheme as per section 231, the profits and gains of such company from such business shall be computed as per other provisions of this Act. (7) Subject to the other provisions of this Part,–– (a) the tonnage income, shall be–– (i) computed as per section 227; and (ii) deemed to be the profits chargeable under the head “Profits and gains of business or profession”; and (b) the relevant shipping income referred to in section 228(1) shall not be chargeable to tax. Direct Taxes Committee 3 2 4

Shahi & Co. — Our Understanding
This section is part of Chapter XII of the Income Tax Act, 2025, effective from 1 April 2026. It carries forward the corresponding provision from the Income Tax Act, 1961 with simplified language and restructured drafting.
Practical Note: For specific guidance on how this provision applies to your situation, consult a qualified Chartered Accountant. The Income Tax Act, 2025 retains the substance of the old law while making it more accessible.
Shahi & Co., Chartered Accountants
Need guidance on Section 226?
Our Direct Tax team advises individuals, businesses, and start-ups on all provisions of the Income Tax Act, 2025. We help you navigate the transition from the old Act with zero disruption to your compliance calendar.
Consult Our Tax Team →
← Previous
Section 225: Income from the business of operating qualify
Next →
Section 227: Computation of tonnage income
← Full IT Act 2025 Index ESOP Taxation Guide TDS under IT Act 2025 NRI Residency Rules
Disclaimer: This is a reproduction of Section 226 of the Income Tax Act, 2025 (No. 30 of 2025) as published in the Official Gazette of India (CG-DL-E-22082025-265620) for informational and reference purposes only. Shahi & Co., Chartered Accountants makes no warranty as to completeness or accuracy. For the official authenticated text refer to egazette.gov.in or incometaxindia.gov.in. This does not constitute legal or tax advice.