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Payments to non-resident agents for services and solicitation carried out outside India do not constitute income accrued or arising in India, so they are not chargeable to Indian tax and do not attract the obligation to deduct tax at source under Section 195; reliance on the Supreme Court authority in CIT v. Toshoku Limited supports this principle. Applying that test, the assessment-level disallowance of commission expenses for non-deduction of tax was reversed and the commission payments were held not taxable in India, resulting in deletion of the disallowance.
Payments to non-resident agents for services and solicitation carried out outside India do not constitute income accrued or arising in India, so they are not chargeable to Indian tax and do not attract the obligation to deduct tax at source under Section 195; reliance on the Supreme Court authority in CIT v. Toshoku Limited supports this principle. Applying that test, the assessment-level disallowance of commission expenses for non-deduction of tax was reversed and the commission payments were held not taxable in India, resulting in deletion of the disallowance.
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