https://www.taxtmi.com/caselaws?id=219823 Export commission paid to non-resident agents for services rendered outside India is not chargeable to tax in India where the agents have no permanent establishment and the payment is not for managerial, technical or consultancy services; in that situation, no tax is deductible at source under section 195 and disallowance under section 40(a)(ia) does not arise. Retention money withheld under contract does not accrue as income until the stipulated contractual conditions for release are satisfied, because no enforceable right to receive the amount exists before then. en-us Fri, 26 Oct 2012 00:00:00 +0530 Tue, 05 Apr 2016 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219823 Export commission paid to non-resident agents for services rendered outside India is not chargeable to tax in India where the agents have no permanent establishment and the payment is not for managerial, technical or consultancy services; in that situation, no tax is deductible at source under section 195 and disallowance under section 40(a)(ia) does not arise. Retention money withheld under contract does not accrue as income until the stipulated contractual conditions for release are satisfied, because no enforceable right to receive the amount exists before then. Case-Laws Income Tax Fri, 26 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219823