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<h1>Clarification on Taxation of Freight Charges for Non-Resident Shipping Companies u/s 172 of Income Tax Act 1961.</h1> The circular addresses the taxation of freight charges for non-resident shipping companies under Section 172 of the Income Tax Act, 1961. It discusses the issue of double taxation on freight charges when goods are transported from Indian ports to intermediate ports by feeder ships and then to final destinations by mother ships. The document clarifies that current laws do not allow deductions for expenses incurred by mother ships, including payments to feeder ships, as the income is deemed and taxed at 7.5%. It suggests that taxation should be based on the apportioned freight charges earned by each segment of the journey, not on the combined total.