Tribunal held that the assessee made payments on behalf of its clients as Clearing and Forwarding Agent which were reimbursed to assessee. Assessee did not make claim of deduction in P & L A/c.  Since, under domestic Law as well as under DTAA, income received by non-resident airline/shipping companies or their Agents, were not taxable in India, therefore, assessee was not liable to deduct TDS.