https://www.taxtmi.com/caselaws?id=197913 Commission paid to a non-resident export agent for procuring orders abroad was not chargeable to tax in India where the agent rendered services wholly outside India, had no permanent establishment in India, and no operations were shown to have been carried out in India. Such export commission was not treated as managerial, consultancy, or technical fees merely because the rate was high. Since the sum was not chargeable to tax in India, the obligation to deduct tax at source under section 195 did not arise, and the resulting disallowance under section 40(a)(ia) was deleted. en-us Thu, 10 Dec 2015 00:00:00 +0530 Thu, 18 Jan 2018 08:22:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=197913 Commission paid to a non-resident export agent for procuring orders abroad was not chargeable to tax in India where the agent rendered services wholly outside India, had no permanent establishment in India, and no operations were shown to have been carried out in India. Such export commission was not treated as managerial, consultancy, or technical fees merely because the rate was high. Since the sum was not chargeable to tax in India, the obligation to deduct tax at source under section 195 did not arise, and the resulting disallowance under section 40(a)(ia) was deleted. Case-Laws Income Tax Thu, 10 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=197913