https://www.taxtmi.com/caselaws?id=761087 ITAT Delhi held that TDS under Section 195 was not applicable on commission payments made to non-resident agents for services rendered outside India. The assessee hired foreign agents in countries where it lacked physical presence to assist in contract procurement. Since the commission payments were for services performed outside India, they were not chargeable to tax in India. Without tax chargeability, Section 195 provisions were not attracted. The CIT(A)'s relief to the assessee was upheld, consistent with the Tribunal's earlier decision for Assessment Year 2017-18. Revenue's appeal was dismissed. en-us Thu, 24 Oct 2024 00:00:00 +0530 Tue, 05 Nov 2024 07:37:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761087 ITAT Delhi held that TDS under Section 195 was not applicable on commission payments made to non-resident agents for services rendered outside India. The assessee hired foreign agents in countries where it lacked physical presence to assist in contract procurement. Since the commission payments were for services performed outside India, they were not chargeable to tax in India. Without tax chargeability, Section 195 provisions were not attracted. The CIT(A)'s relief to the assessee was upheld, consistent with the Tribunal's earlier decision for Assessment Year 2017-18. Revenue's appeal was dismissed. Case-Laws Income Tax Thu, 24 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761087