https://www.taxtmi.com/caselaws?id=780561 ITAT MUMBAI - AT held that commission paid to overseas agents and foreign warehousing charges constituted business income arising outside India, not fees for technical services or income deemed to accrue in India. Relying on the SC principle that s.195 duty to deduct arises only if payment is chargeable to tax in India, the Tribunal found no business connection or PE in India and no territorial nexus. Consequently s.195 liability did not arise and the s.40(a)(ia) disallowance was set aside; appeal allowed. en-us Tue, 30 Sep 2025 00:00:00 +0530 Sat, 01 Nov 2025 08:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780561 ITAT MUMBAI - AT held that commission paid to overseas agents and foreign warehousing charges constituted business income arising outside India, not fees for technical services or income deemed to accrue in India. Relying on the SC principle that s.195 duty to deduct arises only if payment is chargeable to tax in India, the Tribunal found no business connection or PE in India and no territorial nexus. Consequently s.195 liability did not arise and the s.40(a)(ia) disallowance was set aside; appeal allowed. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780561