IT Act 1961 → 2025 / Sections 115V–115VZC
Business incomeTonnage tax scheme for shipping companies
Sections 115V–115VZC of the old Income-tax Act, 1961 · new sections 225–235 under the Income-tax Act, 2025
New reference Sections 225 to 235 (tonnage tax scheme)
Applies to FY 2025-26 (AY 2026-27) and earlier years.
Applies from tax year 2026-27 (from 1 April 2026).
| 1961 Act | Subject | 2025 Act |
|---|---|---|
| 115V | Definitions (tonnage tax) | 235 |
| 115VA | Computation of profits and gains from the business of operating qualifying ships | 225 |
| 115VB | Operating ships | 226(1) |
| 115VC | Qualifying Company | 235(h) |
| 115VD | Qualifying Ship | 235(i) |
| 115VE | Manner of computation of income under tonnage tax scheme | 226(2) to (6) |
| 115VF | Tonnage income | 226(7) |
| 115VG | Computation of tonnage income | 227(1) to (6) |
| 115VH | Calculation in case of joint operation, etc | 227(7) & (8) |
| 115V-I | Relevant shipping income | 228(1) to (13) |
| 115VJ | Treatment of common costs | 228(14) & (15) |
| 115VK | Depreciation | 229(1) to (7) |
| 115VL | General exclusion of deduction and set off, etc | 230(1) |
| 115VM | Exclusion of loss | 230(2) to (4) |
| 115VN | Chargeable gains from transfer of tonnage tax assets | 229(8) to (10) |
| 115V-O | Exclusion from provisions of section 115JB | 228(16) |
| 115VP | Method and time of opting for tonnage tax scheme | 231(1) to (7) |
| 115VQ | Period for which tonnage tax option to remain in force | 231(8) & (9) |
| 115VR | Renewal of tonnage tax scheme | 231(10) & (11) |
| 115VS | Prohibition to opt for tonnage tax scheme in certain cases | 231(12) |
| 115VT | Transfer of profits to Tonnage Tax Reserve Account | 232(1) to (11) |
| 115VU | Minimum training requirement for tonnage tax company | 232(12) to (14) |
| 115VV | Limit for charter in of tonnage | 232(15) to (20) |
| 115VW | Maintenance of audit of accounts | 232(21) |
| 115VX | Determination of tonnage | 227(9) |
| 115VY | Amalgamation | 233(1) to (4) |
| 115VZ | Demerger | 233(5) & (6) |
| 115VZA | Effect of temporarily ceasing to operate qualifying ships | 232(22) & (23) |
| 115VZB | Avoidance of tax and exclusion from tonnage tax scheme | 234(1) to (3) |
| 115VZC | Exclusion from tonnage tax scheme | 234(4) to (7) |
Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.
Renumbered and regrouped: 30 sections of the 1961 Act are folded into 11 sections (225–235) of the 2025 Act, mostly by turning old sections into sub-sections. The scheme itself is carried over. Finance Act 2026 made amendments to sections 227, 228, 232(12)–(13) (minimum training requirement) and 235.
Sections 225 to 235 of the Income-tax Act, 2025 replace Chapter XII-G (sections 115V to 115VZC) of the 1961 Act.
Yes. Section 232(1) requires 20% or more of the book profit from core shipping activities to be credited to the Tonnage Tax Reserve Account.
Section 115V of the Income-tax Act, 1961 (Definitions (tonnage tax)) corresponds to section 235 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 115VA of the Income-tax Act, 1961 (Computation of profits and gains from the business of operating qualifying ships) corresponds to section 225 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 115VB of the Income-tax Act, 1961 (Operating ships) corresponds to section 226(1) of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 115VC of the Income-tax Act, 1961 (Qualifying Company) corresponds to section 235(h) of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 115VD of the Income-tax Act, 1961 (Qualifying Ship) corresponds to section 235(i) of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 115VE of the Income-tax Act, 1961 (Manner of computation of income under tonnage tax scheme) corresponds to section 226(2) to (6) of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Renumbered and regrouped: 30 sections of the 1961 Act are folded into 11 sections (225–235) of the 2025 Act, mostly by turning old sections into sub-sections. The scheme itself is carried over. Finance Act 2026 made amendments to sections 227, 228, 232(12)–(13) (minimum training requirement) and 235.