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<h1>Tax withholding on export commissions: no TDS where non-resident agents render services abroad and income does not arise in India.</h1> No tax deduction at source is required where payments of export commission and related charges are made to non-resident agents who render services wholly outside India, because such income does not arise in India and payments remitted abroad are not treated as received in India; therefore those payments are allowable expenditure and need not be disallowed under the withholding-linked disallowance rule.