https://www.taxtmi.com/caselaws?id=277244 Commission paid to non-resident foreign agents operating outside India was treated as not accruing or arising in India because the agents rendered services abroad and the amounts were remitted directly overseas. On that basis, no taxable income was found in India and no tax deduction at source was required on the commission payments. The analysis relied on CBDT Circular No. 23 of 1996 and Circular No. 786 of 2000, which state that commission paid to non-resident agents for services outside India is outside Indian tax charge. The disallowance was therefore deleted. en-us Tue, 12 Jun 2012 00:00:00 +0530 Thu, 05 Feb 2026 16:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277244 Commission paid to non-resident foreign agents operating outside India was treated as not accruing or arising in India because the agents rendered services abroad and the amounts were remitted directly overseas. On that basis, no taxable income was found in India and no tax deduction at source was required on the commission payments. The analysis relied on CBDT Circular No. 23 of 1996 and Circular No. 786 of 2000, which state that commission paid to non-resident agents for services outside India is outside Indian tax charge. The disallowance was therefore deleted. Case-Laws Income Tax Tue, 12 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277244