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    <title>2002 (12) TMI 198 - ITAT BOMBAY-E</title>
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    <description>The Tribunal upheld the CIT(A)&#039;s decision, ruling that the assessee was not obligated to deduct tax under Section 195 for remittances to non-resident ship owners. It was determined that the payments did not constitute income accruing in India, as the ship was registered in the Bahamas and lacked a business connection in India. The nature of payments as charter hire charges, not freight charges, was clarified. The Tribunal also emphasized that the place of payment does not determine the place of income accrual, and CBDT circulars supported the non-taxability of the remittances. Appeals by the Revenue were dismissed.</description>
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    <pubDate>Mon, 30 Dec 2002 00:00:00 +0530</pubDate>
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      <title>2002 (12) TMI 198 - ITAT BOMBAY-E</title>
      <link>https://www.taxtmi.com/caselaws?id=59335</link>
      <description>The Tribunal upheld the CIT(A)&#039;s decision, ruling that the assessee was not obligated to deduct tax under Section 195 for remittances to non-resident ship owners. It was determined that the payments did not constitute income accruing in India, as the ship was registered in the Bahamas and lacked a business connection in India. The nature of payments as charter hire charges, not freight charges, was clarified. The Tribunal also emphasized that the place of payment does not determine the place of income accrual, and CBDT circulars supported the non-taxability of the remittances. Appeals by the Revenue were dismissed.</description>
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      <pubDate>Mon, 30 Dec 2002 00:00:00 +0530</pubDate>
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