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of <h1>Non-Resident Agent Export Commission Not Taxable in India; No Tax Deduction Required u/s 195.</h1> The circular clarifies the taxability of export commission payable to non-resident agents for services rendered outside India. It addresses an objection raised by the Comptroller & Auditor General regarding the non-deduction of tax at source under section 195 of the Income-tax Act, 1961. The circular refers to a previous clarification (Circular No. 23, dated 23.7.1969) which states that if a non-resident agent operates outside India, their income is not taxable in India, and no tax is deductible under section 195. Consequently, such expenditure is allowable. The Comptroller & Auditor General has agreed to drop the objection.
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