Tax withholding on export commissions: no TDS where non-resident agents render services abroad and income does not arise in India. 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.