https://www.taxtmi.com/caselaws?id=259835 Disallowance of export commission under tax law was upheld because non-resident brokers did not render services in India, so commission income neither accrued nor arose in India; consequence: payments made from India to non-residents for services performed outside India are not taxable in India. The same source-of-income principle was applied following precedents holding that situs of service performance determines taxability, and mere payment origin in India does not create Indian income. Result: tax withholding obligation was not attracted and relief was granted to the taxpayer. en-us Fri, 14 Nov 2014 00:00:00 +0530 Thu, 05 Feb 2026 16:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259835 Disallowance of export commission under tax law was upheld because non-resident brokers did not render services in India, so commission income neither accrued nor arose in India; consequence: payments made from India to non-residents for services performed outside India are not taxable in India. The same source-of-income principle was applied following precedents holding that situs of service performance determines taxability, and mere payment origin in India does not create Indian income. Result: tax withholding obligation was not attracted and relief was granted to the taxpayer. Case-Laws Income Tax Fri, 14 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259835