https://www.taxtmi.com/caselaws?id=783687 Commission paid by an anonymized exporter to non-resident agents was disallowed under s. 37 on grounds of alleged non-genuineness and non-deduction of TDS. Relying on SC law that a non-resident commission agent operating wholly outside India, without carrying out business operations in India, is not chargeable to tax in India under s. 9(1)(i) and its Explanation, the ITAT held that no tax was deductible at source on such overseas commission and the expenditure could not be disallowed on that basis. Following consistency with earlier years in the same assessee's case, the ITAT upheld CIT(A)'s deletion of the addition and dismissed the Revenue's appeal. en-us Thu, 18 Dec 2025 00:00:00 +0530 Sat, 20 Dec 2025 07:45:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783687 Commission paid by an anonymized exporter to non-resident agents was disallowed under s. 37 on grounds of alleged non-genuineness and non-deduction of TDS. Relying on SC law that a non-resident commission agent operating wholly outside India, without carrying out business operations in India, is not chargeable to tax in India under s. 9(1)(i) and its Explanation, the ITAT held that no tax was deductible at source on such overseas commission and the expenditure could not be disallowed on that basis. Following consistency with earlier years in the same assessee's case, the ITAT upheld CIT(A)'s deletion of the addition and dismissed the Revenue's appeal. Case-Laws Income Tax Thu, 18 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783687