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    <title>2012 (10) TMI 431 - ITAT HYDERABAD</title>
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    <description>The ITAT upheld the CIT (A)&#039;s decision that the commission paid to non-resident agents was not taxable in India. Therefore, no tax deduction at source under Section 195(1) was required, and the disallowance under Section 40(a)(i) was unjustified. The Revenue&#039;s appeal was dismissed as the commission payments were not subject to tax in India, with the ITAT finding no evidence supporting the claim that payments were made at the foreign agents&#039; request or received in India.</description>
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      <link>https://www.taxtmi.com/caselaws?id=217493</link>
      <description>The ITAT upheld the CIT (A)&#039;s decision that the commission paid to non-resident agents was not taxable in India. Therefore, no tax deduction at source under Section 195(1) was required, and the disallowance under Section 40(a)(i) was unjustified. The Revenue&#039;s appeal was dismissed as the commission payments were not subject to tax in India, with the ITAT finding no evidence supporting the claim that payments were made at the foreign agents&#039; request or received in India.</description>
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      <pubDate>Fri, 06 Jul 2012 00:00:00 +0530</pubDate>
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