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2006 (9) TMI 546 - HC - Income TaxTDS u/s 194C - Payments made to agents of non-resident shipping companies - In respect of Ocean Freight and Inland Haulage Charges (IHC) - bills of lading - scope of Section 172 in the context of Section 194C - HELD THAT:- We are of the view that the question whether the payees in the instant case, were agents of the non-resident shipping companies is a question of fact, which has been decided against the Revenue concurrently by both the CIT (Appeals) as well as the ITAT. As already noticed, both the CIT (Appeals) as well as the ITAT have based their conclusions upon an appreciation of the evidence and held that in the facts and circumstances of the present case, the provisions of Section 194C of the Act are not attracted. We, accordingly, hold that no substantial question of law arises in this appeal - The appeal is, accordingly, dismissed.
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