Assessment  was completed u/s 143 (3) of the Act. PCIT revised the order on the ground that   the assessee has not deducted tax at source in respect export freight to shipping agent of non-resident ship owner or charter without deduction of tax at source  hence entire amount to be disallowed . On appeal the Appellate Tribunal relying on the Circular No 723 dt 19-9 1995 held that where payment was made to shipping agent of non-resident ship owner or charter, agent would step into shoe of principal, i.e., shipping company and accordingly provisions of section 172, which provide for shipping business in respect of non-residents, would be applicable and provisions of section 194C or section 195, which provide for deduction of tax at source, shall not be applicable. Accordingly the revision order was quashed . On appeal by the revenue High Court affirmed the order of the Tribunal .  (AY. 2013 -14 )