https://www.taxtmi.com/caselaws?id=258309 Disallowance under the tax provision for failure to deduct tax at source on export commission paid to a non-resident was rejected because the non-resident acted as an overseas selling agent and performed services outside India; therefore the payments did not attract the source-based tax provision and were not fees for technical services. The tribunal and appellate authority applied precedents holding that such commission for procuring export orders is outside the chargeability rule, so no withholding obligation arose and the disallowance was deleted, favouring the taxpayer. en-us Tue, 24 Mar 2015 00:00:00 +0530 Thu, 05 Feb 2026 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258309 Disallowance under the tax provision for failure to deduct tax at source on export commission paid to a non-resident was rejected because the non-resident acted as an overseas selling agent and performed services outside India; therefore the payments did not attract the source-based tax provision and were not fees for technical services. The tribunal and appellate authority applied precedents holding that such commission for procuring export orders is outside the chargeability rule, so no withholding obligation arose and the disallowance was deleted, favouring the taxpayer. Case-Laws Income Tax Tue, 24 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258309