Assessee-company made payment to overseas parties as shipment clearing and forwarding charges. Assessing Officer  held that  as per terms of contract between them, assessee was provided with information regarding tariff which would have influenced decision making process and, thus, such services fell under category of consultancy services and payments made to parties were liable for deduction of tax at source. AO   invoked provisions of section 40(a)(i) and disallowed payment. Commissioner (Appeals) held  that payment received by overseas parties neither fell under section 9(1) nor under section 9(1)(vii) and since income could not be described as deemed to accrue or arise in India, taxability of such amount failed and, accordingly, deleted disallowance. On appeal the Tribunal  affirmed the order of the CIT(A). (AY. 2017-18, 2018-19)