https://www.taxtmi.com/caselaws?id=762443 ITAT Rajkot held that TDS u/s 195 was not applicable on commission payments to non-resident parties for services rendered outside India. The recipients had no permanent establishment or business connection in India, and services were provided outside India for selling goods overseas. Since the non-residents were not liable to tax in India under the Income Tax Act, 1961, no TDS obligation arose and disallowance u/s 40(a)(i) was not warranted. The assessee's appeal was allowed. en-us Tue, 17 Sep 2024 00:00:00 +0530 Sat, 30 Nov 2024 10:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762443 ITAT Rajkot held that TDS u/s 195 was not applicable on commission payments to non-resident parties for services rendered outside India. The recipients had no permanent establishment or business connection in India, and services were provided outside India for selling goods overseas. Since the non-residents were not liable to tax in India under the Income Tax Act, 1961, no TDS obligation arose and disallowance u/s 40(a)(i) was not warranted. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 17 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762443