https://www.taxtmi.com/caselaws?id=289465 Export commission paid to non-resident agents for procuring orders abroad is treated as commission simpliciter, rather than managerial, technical or consultancy services. Where agents perform no activities in India and have no permanent establishment in India, the commission does not accrue or arise in India under section 9. Consequently, no tax deduction obligation arises under section 195, and disallowance under section 40(a)(i) does not apply. An advance ruling binds only within the scope 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 Export commission paid to non-resident agents for procuring orders abroad is treated as commission simpliciter, rather than managerial, technical or consultancy services. Where agents perform no activities in India and have no permanent establishment in India, the commission does not accrue or arise in India under section 9. Consequently, no tax deduction obligation arises under section 195, and disallowance under section 40(a)(i) does not apply. An advance ruling binds only within the scope 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