https://www.taxtmi.com/caselaws?id=238371 Commission paid to non-resident export agents for services rendered outside India was treated as not chargeable to tax in India because the agents had no office or business establishment in India, and the services were neither managerial nor technical under section 9(1)(vii) of the Income-tax Act, 1961. In the absence of a permanent establishment in India, the receipts were not taxable as business profits under Article 7 of the applicable tax treaty, and Article 22 did not change that position. As the income was not chargeable in India, no obligation to deduct tax at source arose under section 195, and the related exposure under sections 201(1) and 201(1A) did not survive. en-us Fri, 04 Oct 2013 00:00:00 +0530 Thu, 05 Feb 2026 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238371 Commission paid to non-resident export agents for services rendered outside India was treated as not chargeable to tax in India because the agents had no office or business establishment in India, and the services were neither managerial nor technical under section 9(1)(vii) of the Income-tax Act, 1961. In the absence of a permanent establishment in India, the receipts were not taxable as business profits under Article 7 of the applicable tax treaty, and Article 22 did not change that position. As the income was not chargeable in India, no obligation to deduct tax at source arose under section 195, and the related exposure under sections 201(1) and 201(1A) did not survive. Case-Laws Income Tax Fri, 04 Oct 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238371