a) Section 172 deals with shipping business of non-residents and as per section 172(1) the provisions of sections 194C and 195 relating to tax deduction at source are not applicable.
b) Section 194C applies to payments made to any "resident" and section 172 operates in the area of computation of profits from shipping business of “non-residents”. Thus, there is no overlapping in the areas of operation of these sections.
However, no TDS shall be deducted in case of payments made to shipping agents of non-resident ship-owners or charterers for carriage of passengers etc., shipped at a port in India as the agents acts on behalf of the non-resident ship-owner or charterer and they steps into the shoes of the principal.
Reference Circular no 723 dated 19-09-1995