https://www.taxtmi.com/caselaws?id=260783 Whether export commission payments to nonresident overseas agents constitute fee for technical services was examined: the tribunal held that the auxiliary limb cannot be invoked if the primary feeforservice concept is inapplicable, and no evidence showed any technical services element in procuring export orders; precedent treating export commission as nonFTS was followed and highercourt authority distinguishing earlier contrary authority was noted. Consequently the disallowance under domestic withholding provisions was deleted and the assessment resolved in favour of the taxpayer. en-us Wed, 04 Feb 2015 00:00:00 +0530 Thu, 05 Feb 2026 16:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260783 Whether export commission payments to nonresident overseas agents constitute fee for technical services was examined: the tribunal held that the auxiliary limb cannot be invoked if the primary feeforservice concept is inapplicable, and no evidence showed any technical services element in procuring export orders; precedent treating export commission as nonFTS was followed and highercourt authority distinguishing earlier contrary authority was noted. Consequently the disallowance under domestic withholding provisions was deleted and the assessment resolved in favour of the taxpayer. Case-Laws Income Tax Wed, 04 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260783