S. 40(a)(ia): Amounts not deductible-Deduction at source-Non-resident-Shipping business-Where agents act on behalf of non-resident ship-owners or charterers, they would step into shoes of principal and hence, provision of section 172 would apply and not provision of sections 194C and 195-Not liable to deduct tax at source.[S. 171, 194C, 195, 260A]
PCIT v. Bajaj Herbals (P.) Ltd. (2023) 335 CTR 530 / 148 taxmann.com 147 (Guj)( HC)