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    <title>2014 (1) TMI 1074 - ITAT JODHPUR</title>
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    <description>Payments to clearing and forwarding agents were analysed by separating reimbursement of out-of-pocket expenditure from agency charges, with the reimbursement element treated as lacking an income component and therefore not attracting tax deduction at source under section 194C. Charges linked to shipping-line activity were also considered under the special regime referred to in section 172(8), and the assessee was noted to have supported its position with bills and debit notes. On that basis, the discussion records that only identifiable disallowable components, if any, could be retained, and the major disallowance was not interfered with.</description>
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      <description>Payments to clearing and forwarding agents were analysed by separating reimbursement of out-of-pocket expenditure from agency charges, with the reimbursement element treated as lacking an income component and therefore not attracting tax deduction at source under section 194C. Charges linked to shipping-line activity were also considered under the special regime referred to in section 172(8), and the assessee was noted to have supported its position with bills and debit notes. On that basis, the discussion records that only identifiable disallowable components, if any, could be retained, and the major disallowance was not interfered with.</description>
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