Held that payment of freight charges to a Korean company for availing logistics services in connection with shipment of goods from various ports outside India to India is not royalty hence not liable to deduct tax at source. Order of CIT(A) deleting the disallowance is affirmed. (AY. 2015-16)
DCIT v. Doosan Power Systems India (P.) Ltd. (2025) 210 ITD 99 (Chennai) (Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Royalty-Freight charges-Not royalty-Not liable to deduct tax at source-No disallowance can be made-DTAA-India-Korea.[S.9(1)(vi), 195, Art. 12]
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