https://www.taxtmi.com/caselaws?id=355547 The Tribunal held that the commission paid to foreign agents was not taxable in India as the services were rendered outside India, with no permanent establishment or business connection in India. Therefore, there was no requirement to deduct tax under section 195. The Tribunal affirmed the CIT(A)'s decision to eliminate the disallowance under section 40(a)(ia) and rejected the Revenue's appeal. This ruling aligned with the precedents set in the Supreme Court cases of Toshoku and GE India Technology Centre Pvt. Ltd., emphasizing that income not subject to taxation in India is not subject to TDS provisions. en-us Thu, 08 Feb 2018 00:00:00 +0530 Wed, 14 Feb 2018 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355547 The Tribunal held that the commission paid to foreign agents was not taxable in India as the services were rendered outside India, with no permanent establishment or business connection in India. Therefore, there was no requirement to deduct tax under section 195. The Tribunal affirmed the CIT(A)'s decision to eliminate the disallowance under section 40(a)(ia) and rejected the Revenue's appeal. This ruling aligned with the precedents set in the Supreme Court cases of Toshoku and GE India Technology Centre Pvt. Ltd., emphasizing that income not subject to taxation in India is not subject to TDS provisions. Case-Laws Income Tax Thu, 08 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355547