Assessee had paid ship hiring charges to non-resident company. Assessing Officer held  that amount paid for hiring of ship on time charter basis was chargeable to tax as assessee had paid rent for sailing ship in Indian water, which is not international traffic and, thus, income to non-resident ship owner had accrued in India and, therefore, assessee was liable to deduct TDS and pay same to Government account as per provisions of section 195.Since assessee had not deducted TDS from said payment, Assessing Officer made disallowance under section 40(a)(i) of the Act.  On appeal the Tribunal held that since Assessing Officer totally ignored NOCs issued by department allowing ship for sailing in Indian Port as payment was on time charter basis, Assessing Officer was not justified in making said disallowance. (AY. 2005-06)