Tax deduction at source: TDS provisions do not apply to payments for voyages governed by section 172. A separate voyage wise levy and recovery regime governs tax on shipping income of non residents, operating ship wise and journey wise and displacing general TDS provisions for payments related to such voyages. Agents acting on behalf of non resident ship owners or charterers are regarded as stepping into the shoes of the non resident principal, so the non resident shipping tax code applies rather than resident focused TDS rules for carriage or works contracts.