https://www.taxtmi.com/caselaws?id=289465 Commission paid to non-resident agents for procuring export orders abroad was treated as commission simpliciter, not managerial, technical or consultancy fees. Because the agents rendered services outside India, carried on no activity in India, and had no permanent establishment in India, no income accrued or arose in India and the withholding obligation under section 195 did not arise. On that basis, disallowance under section 40(a)(i) was not attracted. The note also states that an advance ruling binds only within the limits of section 245S and cannot override contrary binding High Court authority. en-us Thu, 08 Oct 2015 00:00:00 +0530 Fri, 07 Aug 2020 18:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289465 Commission paid to non-resident agents for procuring export orders abroad was treated as commission simpliciter, not managerial, technical or consultancy fees. Because the agents rendered services outside India, carried on no activity in India, and had no permanent establishment in India, no income accrued or arose in India and the withholding obligation under section 195 did not arise. On that basis, disallowance under section 40(a)(i) was not attracted. The note also states that an advance ruling binds only within the limits of section 245S and cannot override contrary binding High Court authority. Case-Laws Income Tax Thu, 08 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289465