No withholding tax on freight paid to German Co. as it wasn't taxable as per Article 8 of India-Germ

IT : In terms of article 8 of India Germany DTAA, assessee was not required to deduct tax at source on freight payments made to German carrier in respect of export of goods, - However, payments to Indian agents of German carrier otherwise than on account of airfreight payable to their principal are open to deduction at source under section 194C