Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
Commission paid to non-resident agents for procuring export orders through services rendered outside India is not chargeable to tax in India merely because it relates to an Indian exporter's business. Tax deduction at source on such payments arises only where the income is chargeable to tax in India. In the absence of material showing that the agents rendered services in India or maintained a permanent establishment or business operations in India, the commission remains outside Indian tax charge. Consequently, no tax was deductible on the foreign commission payments, and the corresponding disallowance for non-deduction of tax at source was deleted.
Commission paid to non-resident agents for procuring export orders through services rendered outside India is not chargeable to tax in India merely because it relates to an Indian exporter's business. Tax deduction at source on such payments arises only where the income is chargeable to tax in India. In the absence of material showing that the agents rendered services in India or maintained a permanent establishment or business operations in India, the commission remains outside Indian tax charge. Consequently, no tax was deductible on the foreign commission payments, and the corresponding disallowance for non-deduction of tax at source was deleted.
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