https://www.taxtmi.com/caselaws?id=464319 The article examines TDS liability on freight paid abroad to non-resident shipowners for goods shipped outside India but delivered in India, focusing on whether such income remains outside Indian tax charge under Section 44B and whether Sections 40(a)(i), 195 and 9 can apply despite that special provision. It also discusses CBDT Instruction No. 1934, including its stated exemption for ocean freight payments made outside India on import of cargo, its binding effect under Section 119, and whether it applies to private companies as well as public sector undertakings or to time charter arrangements. en-us Mon, 28 Jul 2025 00:00:00 +0530 Fri, 17 Oct 2025 19:17:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464319 The article examines TDS liability on freight paid abroad to non-resident shipowners for goods shipped outside India but delivered in India, focusing on whether such income remains outside Indian tax charge under Section 44B and whether Sections 40(a)(i), 195 and 9 can apply despite that special provision. It also discusses CBDT Instruction No. 1934, including its stated exemption for ocean freight payments made outside India on import of cargo, its binding effect under Section 119, and whether it applies to private companies as well as public sector undertakings or to time charter arrangements. Case-Laws Income Tax Mon, 28 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464319