Foreign Shipping Payments Not 'Royalty' Under Sec 9(1)(b)(ii) or DTAA; No TDS Liability Under Sec 195.

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....TDS u/s 195 - charter payments (hire charges) to Foreign Shipping Companies - the amount paid by the assessee to the FSC on time charter agreement would not amount to ‘royalty’ neither under Explanation 2 or under section 9(1)(b)(ii) or under the DTAA and in this case only section 172 applies - No TDS liability - AT....