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)