GOVERNMENT OF INDIA
MINISTRY OF FINANCE
INCOME TAX DEPARTMENT
OFFICE OF THE ASSISTANT
COMMISSIONER OF INCOME TAX
INT TAX CIRCLE 2(1)(1), MUMBAI
To,
CMA CGM S A
INDIABULLS FINACE CENTRE TOWER 3 8TH
FLOOR,SENAPATI BAPAT MARG ELPHINSTONE ROAD
WEST
MUMBAI 400013,Maharashtra
India
PAN:
AABCC9048G
Dated:
20/07/2020
DIN & Letter No :
ITBA/COM/F/17/2020-21/1027542049(1)
Sir/ Madam/ M/s,
Subject: Sub: Grant of 100% DIT Relief in respect of M/s CMA CGM S.A., France for F.Y.2020-21 -
reg
Ref: 1) Your submission dated 28.03.2020, 23.06.2020, 27.06.2020 and 08.07.2020
*ITBA100027521647*
Note: If digitally signed, the date of digital signature may be taken as date of document.
ROOM NO:1713,17th Floor, AIR INDIA BUILDING, NARIMAN POINT, MUMBAI, Maharashtra, 400021
Email: [email protected], Office Phone:02222029410
* DIN- Document identification No.
M/s CMA CGM SA, France(PAN- AABCC9048G) has applied for a 100% DIT Relief
Certificate through its agent in India, M/s CMA CGM Agencies (India) Private Limited(PAN-
AADCC3951G) on 28.03.2020 and subsequent letters for its 30 vessels and for the pool
arrangement with 19 shipping companies for the F.Y. 2020-21. On perusal of the same, it is
certified that shipping income is earned by your principal from operation of following vessels
listed below.
The applications as well as the documents, filed in this regard were perused. On
prima facie examination of the documents and details, it appears that principal is entitled for
the benefit of Article 9 of the DTAA between India and France. In view of this, the principal is
entitled for 100% DIT Relief on account of income from operation of the following 30 vessels
operating in the international traffic, i.e. freight and other ancillary charges in connection with
such transportation, which are either owned or chartered by principal for transportation of
passengers, mail, livestock or goods carried on by the principal within Indian ports. However,
any income earned for the transportation of passengers, mail, livestock or goods from one
place to another place within India is not covered by this DIT Relief Certificate.
Sr. No. Name of the Vessel Sr. No. Name of the Vessel
1
ALS FLORA
16
CMA CGM BUTTERFLY
2
CMA CGM JAMAICA
17
CMA CGM MEDEA
It is also certified that shipping income earned by Principal on Pool Arrangement with
following companies/Lines will also be entitled for 100% DIT relief on account of income from
operation of the vessels as per the vessel sharing agreements, in respect of which DIT relief
is granted and which are operating in the international traffic.
Sr. No. Name of the Shipping Line
1 Hapag-Lloyd AG
2 A.P.L. Co. Pte Ltd.
3
SEASPAN LEBU
18
AS CYPRIA
4
IRENES RHYTHM
19
BERMUDA
5
MS EAGLE
20
CMA CGM URUGUAY
6
NORO
21
LOUSIE
7
LYME BAY
22
EDISON
8
APL SAVANNAH
23
BALTIC BRIDGE
9
APL CHONGQING
24
CMA CGM IVANHOE
10
CMA CGM RABELAIS
25
GLACIER BAY
11
CMA CGM RACINE
26
KUMASI
12
CMA CGM ALMAVIVA
27
CMA CGM MOLIERE
13
CMA CGM TITUS
28
APL OREGON
14
JPO VIRGO
29
CPO NORFOLK
15
ROSSINI
30
APL COLUMBUS
Page 2 of 4
AABCC9048G- CMA CGM S A
ITBA/COM/F/17/2020-21/1027542049(1)
3 Nippon Yusen Kaisha - ("NYK")
4 Ocean Network Express Pte. Ltd. ("ONE")
5 Orient Overseas Container Line Limited - ("OOCL")
6 ANL Singapore Pte. Ltd.
7 Emirates Shipping Line (Emirates)
8 A.P. Moller Maersk A/S (MSK)
9 Hanjin Shipping Co. Ltd. (HJS)
10 United Arab Shipping Co. S.A.G. (UASC)
11 COSCO Container Lines Company Limited
(COSCON)
12 Pacific International Lines (Pte.) Ltd. (PIL)
13 Mediterranean Shipping Company S.A. (MSC)
14 COSCO Container Lines South East Asia Pte. Ltd.
15 Kawasaki Kisen Kaisha Ltd.
16 RCL Feeder Pte. Ltd.
17 Simatech Shipping Pte. Ltd. / Simatech Shipping Llc
18 T.S. Lines Co. Ltd.
19 Hamburg Sud KG
Page 3 of 4
AABCC9048G- CMA CGM S A
ITBA/COM/F/17/2020-21/1027542049(1)
The certificate is valid for F.Y. 2020-21. This certificate is provisional in nature and subject to
final assessment. This certificate is being issued on an undertaking given by the principal that
the above referred vessels will be operated in ‘International Traffic’ only during the currency
of this certificate.
JAYASHREE MAHENDRA THAKUR
INT TAX CIRCLE 2(1)(1), MUMBAI
(In case the document is digitally signed please
refer Digital Signature at the bottom of the page)
Page 4 of 4
AABCC9048G- CMA CGM S A
ITBA/COM/F/17/2020-21/1027542049(1)
This document is digitally signed
Signer: JAYASHREE MAHENDRA THAKUR
Date: Tuesday, July 21, 2020 2:54 PM
Location: DIRECTRORATE, India
