ITO v. Bajaj Herbals (P.) Ltd. (2021) 191 ITD 41 (Ahb.)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Freight charges-Non-resident ship owner-Not liable to deduct tax at source. [S. 172, 194C]

Held that  in view of special provisions of section 172, no TDS deduction under section 194C was required on payment of  freight charges to an agent of non-resident ship owner or charter on such charges.  (AY. 2009-10)