https://www.taxtmi.com/caselaws?id=440578 Additional evidence under Rule 46A was properly admitted because the material was forwarded to the Assessing Officer, comments were invited, and the assessee had an opportunity to respond; the absence of separately recorded detailed reasons did not invalidate the admission. Commission paid to non-resident agents for marketing and procuring business abroad was not fee for technical services, as the agents were outside India, had no permanent establishment in India, and received payment abroad. The income did not accrue or arise in India, so no withholding obligation arose under section 195 and the related disallowance was deleted. en-us Tue, 18 Jul 2023 00:00:00 +0530 Fri, 21 Jul 2023 00:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440578 Additional evidence under Rule 46A was properly admitted because the material was forwarded to the Assessing Officer, comments were invited, and the assessee had an opportunity to respond; the absence of separately recorded detailed reasons did not invalidate the admission. Commission paid to non-resident agents for marketing and procuring business abroad was not fee for technical services, as the agents were outside India, had no permanent establishment in India, and received payment abroad. The income did not accrue or arise in India, so no withholding obligation arose under section 195 and the related disallowance was deleted. Case-Laws Income Tax Tue, 18 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440578