https://www.taxtmi.com/caselaws?id=342630 Commission paid to an Indian agent for export canvassing was treated as income of the non-resident chargeable in India where the amount was received in India on behalf of the foreign entity and no material showed mere transmission abroad. On that basis, tax deduction at source under section 195(1) was attracted, and disallowance under section 40(a)(i) followed. CBDT Circular No. 786 was held inapplicable because it concerned payments to a non-resident agent operating outside India. The later insertion of section 40(a)(ia) did not assist the assessee, as the disallowance was made under the pre-existing section 40(a)(i). en-us Thu, 27 Apr 2017 00:00:00 +0530 Wed, 30 Aug 2017 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=342630 Commission paid to an Indian agent for export canvassing was treated as income of the non-resident chargeable in India where the amount was received in India on behalf of the foreign entity and no material showed mere transmission abroad. On that basis, tax deduction at source under section 195(1) was attracted, and disallowance under section 40(a)(i) followed. CBDT Circular No. 786 was held inapplicable because it concerned payments to a non-resident agent operating outside India. The later insertion of section 40(a)(ia) did not assist the assessee, as the disallowance was made under the pre-existing section 40(a)(i). Case-Laws Income Tax Thu, 27 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=342630