TDS against payments covered by section 172

Hello Dhawan,

Since it is self explanatory under circular No. 723-Income Tax Dated 19-9-1995 that TDS either u/s 194C or 195 would not be applicable. However due to complexity under TDS provisions, you can take self-declaration from Indian agent of foreign shipping line that section 172 applicable to them and they have paid taxes in compliance of provisions of section 172 of the Income Tax Act alongwith indemnity clause thereto. Since no specific document as such has been prescribed under income tax act in the given case, we need to use our judgement to satisfy AO on rationale behind non deduction of TDS u/s 194C/195

Regards,

Manoj