https://www.taxtmi.com/caselaws?id=411957 Payments made to non-resident agents for canvassing sales orders and earning commission-based marketing charges outside India were not fees for technical or managerial services where the recipients had no permanent establishment in India and the income was taxable in the foreign jurisdiction under the relevant tax treaty. On those facts, disallowance under Section 40(a)(i) for non-deduction of tax at source under Section 195 was not sustainable, and the deletion of the disallowance was upheld. en-us Fri, 06 Aug 2021 00:00:00 +0530 Tue, 07 Sep 2021 08:06:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411957 Payments made to non-resident agents for canvassing sales orders and earning commission-based marketing charges outside India were not fees for technical or managerial services where the recipients had no permanent establishment in India and the income was taxable in the foreign jurisdiction under the relevant tax treaty. On those facts, disallowance under Section 40(a)(i) for non-deduction of tax at source under Section 195 was not sustainable, and the deletion of the disallowance was upheld. Case-Laws Income Tax Fri, 06 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411957