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    <description>Non-deduction of TDS on agency commission to non-resident agents was upheld where the payments were not taxable in India because the services were rendered abroad and the agents had no permanent establishment in India; consequently there was no obligation to deduct tax at source and the assessing disallowance for failure to withhold was deleted by the appellate authority. The decision applies the principle that TDS obligation arises only if the payment is taxable in India, and the appeal was allowed in favour of the assessee by ITAT.</description>
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