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    <title>2021 (6) TMI 1081 - KARNATAKA HIGH COURT</title>
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    <description>The High Court upheld the Tribunal&#039;s decision, ruling that commission payments to non-resident agents were not subject to TDS as services were rendered and payment made outside India. The Court found the services provided did not qualify as technical services under the Income Tax Act, and no business operations were carried out in India. The appeal was dismissed in favor of the assessee, emphasizing the significance of determining service situs and payment location in TDS applicability on non-resident agent commissions.</description>
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      <description>The High Court upheld the Tribunal&#039;s decision, ruling that commission payments to non-resident agents were not subject to TDS as services were rendered and payment made outside India. The Court found the services provided did not qualify as technical services under the Income Tax Act, and no business operations were carried out in India. The appeal was dismissed in favor of the assessee, emphasizing the significance of determining service situs and payment location in TDS applicability on non-resident agent commissions.</description>
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