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    <title>2015 (12) TMI 97 - ITAT MUMBAI</title>
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    <description>Berth hire charges paid to Mumbai Port Trust were analysed on their true substance and treated as consideration for a composite bundle of port-related services and facilities, including maintenance, mooring, harbour support, water supply and infrastructure. Because the payment was not a simple charge for use of land or an anchorage area, it was not characterised as rent. The correct tax deduction treatment was therefore under section 194C as contractual charges, rather than under section 194I as rent.</description>
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