https://www.taxtmi.com/caselaws?id=379977 The tribunal held that the commission paid to non-resident agents for services rendered outside India is not taxable in India if the agents do not have a permanent establishment in India. As a result, the disallowance under Section 40(a)(ia) of the Income Tax Act was not applicable, and tax withholding obligations under Section 195 did not arise. The tribunal's decision was based on the nature of the services provided by the agents and their role in securing business orders, rather than providing technical services. The appeal was dismissed, affirming that the commission paid was not subject to taxation in India. en-us Tue, 30 Apr 2019 00:00:00 +0530 Sat, 11 May 2019 07:15:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=379977 The tribunal held that the commission paid to non-resident agents for services rendered outside India is not taxable in India if the agents do not have a permanent establishment in India. As a result, the disallowance under Section 40(a)(ia) of the Income Tax Act was not applicable, and tax withholding obligations under Section 195 did not arise. The tribunal's decision was based on the nature of the services provided by the agents and their role in securing business orders, rather than providing technical services. The appeal was dismissed, affirming that the commission paid was not subject to taxation in India. Case-Laws Income Tax Tue, 30 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=379977