https://www.taxtmi.com/caselaws?id=327092 Section 195 TDS applies only to sums chargeable to tax in India, so reimbursements of actual logistics expenses paid to overseas agents, being pure pass-through amounts without income element, were outside withholding. The profit component was also not taxable in India because the non-resident entities rendered services wholly outside India, had no permanent establishment, and carried on no operations in India from which income could be attributed under sections 5 and 9 read with the DTAA. Mere agency terminology in the agreements was insufficient to create a dependent-agent permanent establishment. Accordingly, no tax was required to be deducted at source on the remittances. en-us Wed, 27 Apr 2016 00:00:00 +0530 Tue, 03 May 2016 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327092 Section 195 TDS applies only to sums chargeable to tax in India, so reimbursements of actual logistics expenses paid to overseas agents, being pure pass-through amounts without income element, were outside withholding. The profit component was also not taxable in India because the non-resident entities rendered services wholly outside India, had no permanent establishment, and carried on no operations in India from which income could be attributed under sections 5 and 9 read with the DTAA. Mere agency terminology in the agreements was insufficient to create a dependent-agent permanent establishment. Accordingly, no tax was required to be deducted at source on the remittances. Case-Laws Income Tax Wed, 27 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327092