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2022 (9) TMI 836 - AT - Income TaxProfits of non-residents from occasional shipping business u/s 172 - Applicability of provisions u/s 194C - Payments made to agents of Foreign Shipping Companies - Assessee reiterated its contention that it has made payments to agents of foreign shipping companies, therefore, these payments are covered u/s 172 of the Act, and are fully exempt from TDS deduction - HELD THAT:- CBDT Circular No. 723 dated 19.09.1995 clearly states that provisions of section 172 applies to payments made to agents of foreign shipping companies and therefore, provisions of section 194C of the Act do not apply. Since the aforementioned Circular has been followed by the ld. CIT(A), we do not find any reason to interfere with the findings of the ld. CIT(A). - Decided against revenue.
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