https://www.taxtmi.com/caselaws?id=210936 Export commission payable to non-resident agents was held to be deemed to accrue and arise in India because the right to receive commission arises when the order is executed by the payer in India; consequently such commission is taxable under the source rules and the specific domestic income provisions relied upon, and the payer must apply withholding obligations. The applicant did not claim DTAA benefits or statutory exemption, and the authority applied the withholding framework accordingly. en-us Wed, 22 Feb 2012 00:00:00 +0530 Thu, 05 Feb 2026 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210936 Export commission payable to non-resident agents was held to be deemed to accrue and arise in India because the right to receive commission arises when the order is executed by the payer in India; consequently such commission is taxable under the source rules and the specific domestic income provisions relied upon, and the payer must apply withholding obligations. The applicant did not claim DTAA benefits or statutory exemption, and the authority applied the withholding framework accordingly. Case-Laws Income Tax Wed, 22 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210936