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Dispute Over TDS Applicability on Payments to Foreign Freight Agents u/s 40(a)(i) of Income Tax Act.

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....TDS u/s 195 - Disallowance u/s 40(a)(i) - payment made to International Freight Forwarding Agents (related companies) - those foreign companies are independent legal entities in foreign countries and they have no business activity nor any permanent establishment in India and, therefore, cannot automatically have business connection in India just because they are related parties. - HC....

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