https://www.taxtmi.com/caselaws?id=379802 Commission paid to non-resident sales agents for services rendered outside India was not taxable in India because the record showed only forwarding enquiries, obtaining quotes and processing purchase orders, with no proof of managerial, technical or consultancy services or a permanent establishment in India. As the payment did not accrue or deem to accrue in India, no withholding obligation arose under section 195, and disallowance under section 40(a)(i) could not be sustained. The additions relating to the commission payments were deleted. en-us Thu, 18 Apr 2019 00:00:00 +0530 Tue, 07 May 2019 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=379802 Commission paid to non-resident sales agents for services rendered outside India was not taxable in India because the record showed only forwarding enquiries, obtaining quotes and processing purchase orders, with no proof of managerial, technical or consultancy services or a permanent establishment in India. As the payment did not accrue or deem to accrue in India, no withholding obligation arose under section 195, and disallowance under section 40(a)(i) could not be sustained. The additions relating to the commission payments were deleted. Case-Laws Income Tax Thu, 18 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=379802