https://www.taxtmi.com/caselaws?id=274113 Commission paid to a non-resident for services rendered outside India was not chargeable to tax in India because no income arose or accrued in India and the recipient had no permanent establishment in India under the applicable DTAA. As section 195 applies only to sums chargeable under the Act, no tax was deductible at source on the remittance abroad. On that basis, disallowance under section 40(a)(i) was held unsustainable and was deleted, and the revenue appeal failed. en-us Mon, 23 Apr 2018 00:00:00 +0530 Sun, 29 Jul 2018 11:40:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274113 Commission paid to a non-resident for services rendered outside India was not chargeable to tax in India because no income arose or accrued in India and the recipient had no permanent establishment in India under the applicable DTAA. As section 195 applies only to sums chargeable under the Act, no tax was deductible at source on the remittance abroad. On that basis, disallowance under section 40(a)(i) was held unsustainable and was deleted, and the revenue appeal failed. Case-Laws Income Tax Mon, 23 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274113