https://www.taxtmi.com/caselaws?id=178534 ITAT Hyderabad dismissed the Revenue's appeals and upheld CIT(A)'s order. It held that commission paid to non-resident overseas agents for services rendered outside India was not chargeable to tax in India under sections 4, 5 and 9, hence no obligation to deduct TDS under section 195 arose and disallowance under section 40a(ia) was unwarranted. Consequently, export commission payments were allowable as expenditure. On deduction under section 80HHC, the ITAT agreed that the AO was bound by the earlier remand and could recompute 80HHC only for determining book profits under section 115JA, following the Syncome Formulations Special Bench decision. en-us Fri, 25 Mar 2011 00:00:00 +0530 Thu, 27 Nov 2025 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178534 ITAT Hyderabad dismissed the Revenue's appeals and upheld CIT(A)'s order. It held that commission paid to non-resident overseas agents for services rendered outside India was not chargeable to tax in India under sections 4, 5 and 9, hence no obligation to deduct TDS under section 195 arose and disallowance under section 40a(ia) was unwarranted. Consequently, export commission payments were allowable as expenditure. On deduction under section 80HHC, the ITAT agreed that the AO was bound by the earlier remand and could recompute 80HHC only for determining book profits under section 115JA, following the Syncome Formulations Special Bench decision. Case-Laws Income Tax Fri, 25 Mar 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178534