https://www.taxtmi.com/caselaws?id=257785 Nonresident agents engaged solely to procure export orders and paid commission for services performed and remunerated outside India do not create a business operation in India; therefore their commission income is not deemed to accrue or arise in India, and is not taxable under the territorial nexus principle. Applying precedents that distinguish selling agents acting abroad and services completed overseas, the decision concludes that such payments do not constitute fees for technical services and that the provisions governing source taxation and withholding do not apply; consequence: no obligation to deduct tax at source on those commission payments. en-us Mon, 02 Mar 2015 00:00:00 +0530 Thu, 05 Feb 2026 16:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257785 Nonresident agents engaged solely to procure export orders and paid commission for services performed and remunerated outside India do not create a business operation in India; therefore their commission income is not deemed to accrue or arise in India, and is not taxable under the territorial nexus principle. Applying precedents that distinguish selling agents acting abroad and services completed overseas, the decision concludes that such payments do not constitute fees for technical services and that the provisions governing source taxation and withholding do not apply; consequence: no obligation to deduct tax at source on those commission payments. Case-Laws Income Tax Mon, 02 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257785