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    <title>2025 (2) TMI 1473 - ITAT CHENNAI</title>
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    <description>Freight payments made to foreign shipping companies were held to accrue in India because the right to receive freight arose on delivery/unloading at Indian ports; consequence: the aggregate Rs. 8,83,16,208 was upheld as taxable and added under the withholding/disallowance provisions. The tribunal rejected reliance on Instruction No. 1934 and time charter distinctions as inapplicable, and noted absence of 15CA, nil deduction certificates or permanent establishment evidence; consequence: payer&#039;s failure to deduct tax under the withholding regime justified disallowance. The jurisdiction and limitation plea failed for want of supporting evidence and was dismissed.</description>
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      <title>2025 (2) TMI 1473 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=466608</link>
      <description>Freight payments made to foreign shipping companies were held to accrue in India because the right to receive freight arose on delivery/unloading at Indian ports; consequence: the aggregate Rs. 8,83,16,208 was upheld as taxable and added under the withholding/disallowance provisions. The tribunal rejected reliance on Instruction No. 1934 and time charter distinctions as inapplicable, and noted absence of 15CA, nil deduction certificates or permanent establishment evidence; consequence: payer&#039;s failure to deduct tax under the withholding regime justified disallowance. The jurisdiction and limitation plea failed for want of supporting evidence and was dismissed.</description>
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