NWG Cruises Ltd., a non-resident company incorporated in Singapore. operates luxury passenger cruises across Asia. During the FY 25-26, the company…

NWG Cruises Ltd., a non-resident company incorporated in Singapore. operates luxury passenger cruises across Asia. During the FY 25-26, the company undertook multiple cruise voyages, operating in Indian ports as well as internationally. The particulars of the income/receipts of NWG Cruises Ltd. for FY 25-26 are as under: 1.40 crore received from passengers embarking in India for cruises touching Indian ports. 2.5 crore received from cargo services. 3.15 crore received outside India for tickets sold abroad for cruises touching Indian ports. 4.10 crore received for cruises operating entirely outside India (not touching Indian ports). 5.3 crore interest earned (Gross) on fixed deposits maintained with an Indian bank. NWG Cruises Ltd. had taken the cruise ship on lease from TMB Cruises Ltd., a company registered in Singapore, and paid lease rentals of 8 crore during the FY 25-26. Both NWG Cruises Ltd. and TMB Cruises Ltd. are subsidiaries of TLO Cruise Ltd., a holding company incorporated in Singapore. Considering the above facts, compute the taxable income of NWG Cruises Ltd. in India, assuming that special provisions for computing profits and gains of business of operation of cruise ships in case of non-residents inserted with effect from 1st April 2025 under the Income-tax Act, 1961 are applicable and NWG Cruises Ltd. fulfils all the conditions prescribed under the relevant rule of the Income-tax Rules, 1962. Also examine the taxability of lease rental income in the hands of TMB Cruises Ltd. with necessary explanations.