Tribunal held that  the recipients of the amount had deposited the tax due on the sums and reflected the receipts in their returns. Therefore the matter was remanded to the Assessing Officer to decide afresh in view of the proviso to S. 40(a)(ia) read with S.201(1A) of the Act. The AO was also directed to decide afresh the addition of shipping expenses and freight and forwarding charges, in view of the parameters as prescribed under section 172 as well as the other disallowances qua legal expenses, advertising and publicity expenses, freight and forwarding expenses and IHC/THC/C & F expenses in accordance with law. The onus to show that the section 40(a)(i) or 40(a)(ia) was not attracted in the facts and circumstances of the case, was on the assessee. ( AY.2005 -06)