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    <title>2016 (2) TMI 1339 - ITAT JAIPUR</title>
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    <description>Commission paid to non-resident agents for export-related services rendered outside India was treated as not chargeable to tax in India because the services were performed abroad and no business connection in India was found; accordingly, tax deduction at source was not required and the disallowance under section 40(a)(i) was deleted. Employees&#039; contributions to PF and ESI paid before filing the return were also held allowable, as the delayed-payment disallowance was not sustainable on the jurisdictional view relied upon. The Revenue&#039;s appeal failed and the assessee&#039;s cross objection succeeded, resulting in deletion of both disputed disallowances.</description>
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      <title>2016 (2) TMI 1339 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=302049</link>
      <description>Commission paid to non-resident agents for export-related services rendered outside India was treated as not chargeable to tax in India because the services were performed abroad and no business connection in India was found; accordingly, tax deduction at source was not required and the disallowance under section 40(a)(i) was deleted. Employees&#039; contributions to PF and ESI paid before filing the return were also held allowable, as the delayed-payment disallowance was not sustainable on the jurisdictional view relied upon. The Revenue&#039;s appeal failed and the assessee&#039;s cross objection succeeded, resulting in deletion of both disputed disallowances.</description>
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