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The provisions of section 172 are to apply, notwithstanding anything contained in other ' provisions of the Act. Therefore, in such cases, the provisions of sections 194C and 195 relating to tax deduction at source are not applicable. The recovery of tax is to be regulated, for a voyage undertaken from any port in India by a ship under the provisions of section 172.

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Sec. 37 & 194C of Income Tax Act, 1961—Business Expenditure - Where payments are made to shipping agents of non-resident ship-owners or charterers for carriage of passengers etc., shipped at a port in India,since, the agent acts on behalf of the non-resident ship-owner or charterer, he steps into the shoes of the principal, thus, provisions of section 172 shall apply and those of sections 194C and 195 will not apply. - SURESH KHATRI V/s ITO - [2020] 82 ITR (TRIB) 029 (ITAT-LUCKNOW)