https://www.taxtmi.com/caselaws?id=256980 Section 40(a)(ia) disallowance was upheld for freight charges paid to an agent of foreign shipping companies because section 172 was held not to exclude the TDS obligation on the facts, and the relief for tax already paid by the recipient was treated as confined to resident payees. Disallowance was deleted for transportation charges paid to resident transporters who had already discharged tax on the corresponding receipts. Machinery maintenance disallowance was also deleted because part of the expenditure was for purchase of machinery parts outside Chapter XVII-B and the remaining repair bills were below the relevant threshold. The assessee's plea to delete clearing and forwarding disallowance for want of contract failed, as the new factual contention was not accepted and the balance represented agency charges. en-us Thu, 12 Feb 2015 00:00:00 +0530 Wed, 25 Feb 2015 17:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256980 Section 40(a)(ia) disallowance was upheld for freight charges paid to an agent of foreign shipping companies because section 172 was held not to exclude the TDS obligation on the facts, and the relief for tax already paid by the recipient was treated as confined to resident payees. Disallowance was deleted for transportation charges paid to resident transporters who had already discharged tax on the corresponding receipts. Machinery maintenance disallowance was also deleted because part of the expenditure was for purchase of machinery parts outside Chapter XVII-B and the remaining repair bills were below the relevant threshold. The assessee's plea to delete clearing and forwarding disallowance for want of contract failed, as the new factual contention was not accepted and the balance represented agency charges. Case-Laws Income Tax Thu, 12 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256980