TaxTMI 
TaxTMI 
circular no.7/2009(f.no.500/135/2007-ftd-I) dt 22.10.2009 has withdrawn circular 23 dt 23.07.1969, 163 dt 29.05.1975, 786 dt 7.02.2000. in view these whether commission to foreign agents outside india can be paid , whether tds is applicable, what one is to comment in form 15CB.
Applicability of TDS on commission to foreign agents paid outside india.
25 May 2010 
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TDS on commissions to foreign agents may not apply where agents lack permanent establishment, altering withholding obligations.
Commission payments to foreign agents are not subject to tax deduction at source where the agents do not have a permanent establishment in India, and Form 15CB should indicate a nil withholding rate. Administrative rulings may have limited applicability to parties, while judicial decisions on analogous facts can carry persuasive weight when assessing withholding obligations. (AI Summary)
Commission payments to foreign agents are not subject to tax deduction at source where the agents do not have a permanent establishment in India, and Form 15CB should indicate a nil withholding rate. Administrative rulings may have limited applicability to parties, while judicial decisions on analogous facts can carry persuasive weight when assessing withholding obligations. (AI Summary)