https://www.taxtmi.com/caselaws?id=785170 Commission paid to non-resident foreign agents for procuring export orders outside India was treated as income not chargeable to tax in India because the services were rendered outside India and the agents had no permanent establishment in India. On that basis, no obligation to deduct tax at source arose, and a disallowance for non-deduction could not be sustained. The treaty position was applied to the extent it was more beneficial to the assessee, reinforcing that where the underlying payment is outside Indian taxability, withholding consequences do not follow. en-us Thu, 15 Jan 2026 00:00:00 +0530 Mon, 19 Jan 2026 07:36:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785170 Commission paid to non-resident foreign agents for procuring export orders outside India was treated as income not chargeable to tax in India because the services were rendered outside India and the agents had no permanent establishment in India. On that basis, no obligation to deduct tax at source arose, and a disallowance for non-deduction could not be sustained. The treaty position was applied to the extent it was more beneficial to the assessee, reinforcing that where the underlying payment is outside Indian taxability, withholding consequences do not follow. Case-Laws Income Tax Thu, 15 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785170