https://www.taxtmi.com/forum/issue?id=3872 The document analyses whether commission paid to a non resident for securing export orders is taxable and subject to TDS. One view treats such commission as deemed to accrue or arise in India if services are utilized in India, prompting withholding obligations and the option to apply for a withholding determination. The opposing view holds that where services are performed and paid outside India, the agent has no permanent establishment, and activities are confined to export transactions, the commission does not accrue in India and is not taxable nor subject to TDS. en-us Thu, 01 Mar 2012 17:37:17 +0530 Thu, 23 Jan 2025 15:58:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=3872 The document analyses whether commission paid to a non resident for securing export orders is taxable and subject to TDS. One view treats such commission as deemed to accrue or arise in India if services are utilized in India, prompting withholding obligations and the option to apply for a withholding determination. The opposing view holds that where services are performed and paid outside India, the agent has no permanent establishment, and activities are confined to export transactions, the commission does not accrue in India and is not taxable nor subject to TDS. Discussion-Forum Income Tax Thu, 01 Mar 2012 17:37:17 +0530 https://www.taxtmi.com/forum/issue?id=3872