https://www.taxtmi.com/caselaws?id=34287 The ruling determined that the commission paid to Zaikog Trading Co., a South African company, is not taxable in India under Section 195 of the Income-tax Act, 1961, and the Double Taxation Avoidance Agreement (DTAA) between India and South Africa. Zaikog's lack of a permanent establishment in India exempts the commission from taxation, and the services provided do not qualify as fees for technical services. Therefore, Zaikog is not required to file a return of income in India. The ruling was issued on July 29, 2009. en-us Wed, 29 Jul 2009 00:00:00 +0530 Sat, 05 Sep 2009 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34287 The ruling determined that the commission paid to Zaikog Trading Co., a South African company, is not taxable in India under Section 195 of the Income-tax Act, 1961, and the Double Taxation Avoidance Agreement (DTAA) between India and South Africa. Zaikog's lack of a permanent establishment in India exempts the commission from taxation, and the services provided do not qualify as fees for technical services. Therefore, Zaikog is not required to file a return of income in India. The ruling was issued on July 29, 2009. Case-Laws Income Tax Wed, 29 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34287