https://www.taxtmi.com/caselaws?id=260623 Disallowance under section 40(a)(i) was contested for foreign agency commission paid to nonresident agents. ITAT found no permanent establishment or Indiabased agreement, no evidence of technical services, and no proof payments accrued, arose or were paid in India; therefore the payments were not taxable in India and no TDS deduction was required. The tribunal affirmed the CIT(A)'s deletion of the disallowance and decided in favour of the assessee. en-us Fri, 25 Apr 2014 00:00:00 +0530 Thu, 05 Feb 2026 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260623 Disallowance under section 40(a)(i) was contested for foreign agency commission paid to nonresident agents. ITAT found no permanent establishment or Indiabased agreement, no evidence of technical services, and no proof payments accrued, arose or were paid in India; therefore the payments were not taxable in India and no TDS deduction was required. The tribunal affirmed the CIT(A)'s deletion of the disallowance and decided in favour of the assessee. Case-Laws Income Tax Fri, 25 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260623