JUDGMENT :

M.S. SONAK, J.

1. Heard Mr. Chetan Kumar Gouda along with Mr. Menino Pereira for the Appellants and Ms. Amira Razaq, learned Standing Counsel for the Respondent.

2. The learned counsel state that these appeals may be disposed of by a common judgment and order since, the issues involved in all these appeals are virtually identical and also the substantial questions of law as framed, are identical.

3. For convenience, Tax Appeal No. 45 of 2015 is taken as the lead matter.

4. These Tax Appeals were admitted on 05.10.2015 on the following substantial question of law:-

(A) Whether the ITAT failed to realise that since the appellant paid LC Charges/commission charges which are in the nature of bank charges to their own Nationalized Banks based in India towards opening of the Letter of Credit it could not be construed under the 195(1) that such Usance charges were paid or were payable to a non resident supplier and, consequently, was liable to pay TDS?

5. The assesses filed return of income for the Assessment Year 2009-10 returning nil income claiming inter-alia expenditure of Rs. 17,14,806/- as LC Charges and commission paid to the assesses' bankers in India in Indian currency.

6. The