https://www.taxtmi.com/caselaws?id=248739 Payments to overseas agents for procuring export orders and market information were held not taxable in India because services were rendered outside India and reimbursements were paid abroad; no permanent establishment or technical services in India was established, so withholding under the law was not attracted. The appellate finding that no evidence showed agents provided or made available technical services was affirmed, and the statutory withholding claim was rejected, resulting in a decision adverse to Revenue. A cited prior tribunal precedent supported the conclusion that export commission obligations, when performed and paid offshore, do not create an Indian tax withholding liability. en-us Mon, 02 Jun 2014 00:00:00 +0530 Thu, 05 Feb 2026 16:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248739 Payments to overseas agents for procuring export orders and market information were held not taxable in India because services were rendered outside India and reimbursements were paid abroad; no permanent establishment or technical services in India was established, so withholding under the law was not attracted. The appellate finding that no evidence showed agents provided or made available technical services was affirmed, and the statutory withholding claim was rejected, resulting in a decision adverse to Revenue. A cited prior tribunal precedent supported the conclusion that export commission obligations, when performed and paid offshore, do not create an Indian tax withholding liability. Case-Laws Income Tax Mon, 02 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248739