https://www.taxtmi.com/caselaws?id=6592 Commission earned by a non-resident agent from Indian exhibition business was treated as income accruing or arising in India because the right to receive it depended on exhibitors participating in India and paying in India. The fact that services were rendered outside India and commission was remitted abroad did not change the source of income. The treaty did not provide a broader exemption. As the commission was taxable in India, the resident payer was required to deduct tax at source on the remittance to the non-resident agent. en-us Mon, 03 Jul 2006 00:00:00 +0530 Thu, 18 Sep 2025 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6592 Commission earned by a non-resident agent from Indian exhibition business was treated as income accruing or arising in India because the right to receive it depended on exhibitors participating in India and paying in India. The fact that services were rendered outside India and commission was remitted abroad did not change the source of income. The treaty did not provide a broader exemption. As the commission was taxable in India, the resident payer was required to deduct tax at source on the remittance to the non-resident agent. Case-Laws Income Tax Mon, 03 Jul 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6592