Section 172(2)

(2) Where such a ship carries passengers, livestock, mail or goods shipped at a port in India, 2[seven and a half per cent.] of the amount paid or payable on account of such carriage to the owner or the charterer or to any person on his behalf, whether that amount is paid or payable in or out of India, shall be deemed to be income accruing in India to the owner or charterer on account of such carriage.