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Is Tds levey on Airfreight on export

This query is : Resolved 
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(Querist)
30 July 2022 Dear sir
pls help me to confirm about deduction of Tds u/s 194c on Airfreight on export in which case or full exempted
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Adv. Ravish Bhatt, ADIT, CIOT

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Adv. Ravish Bhatt, ADIT, CIOT (Expert)
15 August 2022 Airfreight payment will be resulting in profits of an enterprise from operation of aircraft in International Traffic and, in case of existence of Double Taxation Avoidance Agreement, such profit should be taxable in country where the enterprise operating the aircraft is tax resident and consequently any payment to such enterprise should not be liable for TDS u/s.195 or any other provisions of ITA, 1961.

Check up the relevant Tax Treaty(Mostly Article 8) for an answer. Seek Professional opinion however showing all your relevant facts and documents.
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