https://www.taxtmi.com/caselaws?id=65849 In tea business cases, section 80HHC deduction is computed with reference to income before application of Rule 8 where binding jurisdictional precedent so directs. Payments to non-resident foreign agents for commission, brokerage, warehousing and selling services rendered outside India are not subject to tax deduction at source under section 195 when no income arises or accrues in India; in that situation, disallowance under section 40(a)(i) cannot be made. The commentary applies established appellate and circular-based principles to sustain the assessee's treatment of both issues. en-us Fri, 31 Aug 2007 00:00:00 +0530 Sat, 03 Feb 2024 13:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65849 In tea business cases, section 80HHC deduction is computed with reference to income before application of Rule 8 where binding jurisdictional precedent so directs. Payments to non-resident foreign agents for commission, brokerage, warehousing and selling services rendered outside India are not subject to tax deduction at source under section 195 when no income arises or accrues in India; in that situation, disallowance under section 40(a)(i) cannot be made. The commentary applies established appellate and circular-based principles to sustain the assessee's treatment of both issues. Case-Laws Income Tax Fri, 31 Aug 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65849