https://www.taxtmi.com/caselaws?id=314248 The ITAT Mumbai ruled in favor of the assessee regarding TDS u/s 195 on commission paid to foreign agents. The assessee paid commission to non-resident agents in Italy, France, Greece, and Lebanon for procuring export orders outside India. The Tribunal held that since the services were rendered outside India by agents without any permanent establishment in India, and payments were made outside India under existing DTAAs, the commission income could not be deemed to have accrued or arisen in India. The Tribunal relied on its earlier decisions in the assessee's own case for AY 2010-11 and 2012-13, ruling against the revenue department. en-us Thu, 29 Feb 2024 00:00:00 +0530 Mon, 27 May 2024 21:06:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314248 The ITAT Mumbai ruled in favor of the assessee regarding TDS u/s 195 on commission paid to foreign agents. The assessee paid commission to non-resident agents in Italy, France, Greece, and Lebanon for procuring export orders outside India. The Tribunal held that since the services were rendered outside India by agents without any permanent establishment in India, and payments were made outside India under existing DTAAs, the commission income could not be deemed to have accrued or arisen in India. The Tribunal relied on its earlier decisions in the assessee's own case for AY 2010-11 and 2012-13, ruling against the revenue department. Case-Laws Income Tax Thu, 29 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314248