08 January 2015
No TCS on High Sea Sales whether generated from Manufacturing Activity or not.
The Income Tax Act 1961 extends to whole of India.
India is defined in section 2(25A)
[(25A) "India" means the territory of India as referred to in article 1 of the Constitution, its territorial waters, seabed and subsoil underlying such waters, continental shelf, exclusive economic zone or any other maritime zone as referred to in the Territorial Waters, Continental Shelf, Exclusive Economic Zone and other Maritime Zones Act, 1976 (80 of 1976), and the air space above its territory and territorial waters;]
Therefore High Sea Sales are outside the purview of TCS.