https://www.taxtmi.com/caselaws?id=252614 Commission paid to non-resident foreign agents for services rendered outside India was not chargeable to tax in India in the absence of a permanent establishment, so section 195 was not attracted. On that basis, disallowance under section 40(a)(ia) was unsustainable. The earlier circular governing the assessment year continued to apply, and the later circular could not operate retrospectively to alter the tax position for prior payments. The objection based on business expediency did not raise a substantial issue warranting interference. en-us Tue, 09 Sep 2014 00:00:00 +0530 Thu, 05 Feb 2026 16:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252614 Commission paid to non-resident foreign agents for services rendered outside India was not chargeable to tax in India in the absence of a permanent establishment, so section 195 was not attracted. On that basis, disallowance under section 40(a)(ia) was unsustainable. The earlier circular governing the assessment year continued to apply, and the later circular could not operate retrospectively to alter the tax position for prior payments. The objection based on business expediency did not raise a substantial issue warranting interference. Case-Laws Income Tax Tue, 09 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252614