https://www.taxtmi.com/caselaws?id=176472 A payment to a foreign trading intermediary was treated as commission for export procurement under a principal-agent arrangement, not fees for technical services. The intermediary's role was confined to transferring letters of credit and facilitating execution of the export contract, so the services were commercial in nature and did not amount to managerial, technical, consultancy or similar services. On that construction, section 194J did not apply and no tax deduction at source was required; the assessee was therefore not treated as in default under section 201(1). en-us Thu, 27 Mar 2008 00:00:00 +0530 Thu, 21 Dec 2023 14:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176472 A payment to a foreign trading intermediary was treated as commission for export procurement under a principal-agent arrangement, not fees for technical services. The intermediary's role was confined to transferring letters of credit and facilitating execution of the export contract, so the services were commercial in nature and did not amount to managerial, technical, consultancy or similar services. On that construction, section 194J did not apply and no tax deduction at source was required; the assessee was therefore not treated as in default under section 201(1). Case-Laws Income Tax Thu, 27 Mar 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176472