https://www.taxtmi.com/caselaws?id=444792 Commission paid to non-resident foreign agents for procuring export orders and related commercial support was not disallowable under section 40(a)(i) read with section 195 because the services were neither managerial, technical nor consultancy in nature, and no technical knowledge, skill, experience or know-how was made available under Article 12(4) of the India-USA DTAA; the disallowance was deleted. Interest under section 234A was also held leviable for the relevant assessment year because the statutory filing timeline did not permit exemption on the facts; the levy was upheld. en-us Wed, 11 Oct 2023 00:00:00 +0530 Sat, 21 Oct 2023 09:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444792 Commission paid to non-resident foreign agents for procuring export orders and related commercial support was not disallowable under section 40(a)(i) read with section 195 because the services were neither managerial, technical nor consultancy in nature, and no technical knowledge, skill, experience or know-how was made available under Article 12(4) of the India-USA DTAA; the disallowance was deleted. Interest under section 234A was also held leviable for the relevant assessment year because the statutory filing timeline did not permit exemption on the facts; the levy was upheld. Case-Laws Income Tax Wed, 11 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444792