https://www.taxtmi.com/caselaws?id=362808 Export commission paid to non-resident foreign agents for securing orders abroad was not chargeable to tax in India because the agents had no permanent establishment in India and performed services wholly outside India. The timing of payment after receipt of sale proceeds did not change the character of the income. The commission was not income deemed to accrue or arise in India under section 9(1)(i), and it was not fees for technical services because it was consideration for procuring export orders, not managerial, technical, or consultancy services. As the sums were not taxable in the hands of the payees, no withholding obligation arose under section 195. en-us Wed, 27 Jun 2018 00:00:00 +0530 Wed, 04 Jul 2018 09:27:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362808 Export commission paid to non-resident foreign agents for securing orders abroad was not chargeable to tax in India because the agents had no permanent establishment in India and performed services wholly outside India. The timing of payment after receipt of sale proceeds did not change the character of the income. The commission was not income deemed to accrue or arise in India under section 9(1)(i), and it was not fees for technical services because it was consideration for procuring export orders, not managerial, technical, or consultancy services. As the sums were not taxable in the hands of the payees, no withholding obligation arose under section 195. Case-Laws Income Tax Wed, 27 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362808