https://www.taxtmi.com/caselaws?id=467810 Documents filed before the first appellate authority were treated as supporting clarification of evidence already produced during assessment, not as inadmissible additional evidence requiring remand under Rule 46A, so the evidentiary objection failed. Commission paid to non-resident foreign agents for securing export orders abroad was held not chargeable to tax in India because the agents operated outside India, had no business connection or permanent establishment in India, and the services were not managerial, technical, or consultancy services. As the sums were not income chargeable in India, no withholding obligation arose under Section 195 and the disallowance under Section 40(a)(ia) could not survive. en-us Thu, 21 Aug 2025 00:00:00 +0530 Sat, 04 Apr 2026 08:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467810 Documents filed before the first appellate authority were treated as supporting clarification of evidence already produced during assessment, not as inadmissible additional evidence requiring remand under Rule 46A, so the evidentiary objection failed. Commission paid to non-resident foreign agents for securing export orders abroad was held not chargeable to tax in India because the agents operated outside India, had no business connection or permanent establishment in India, and the services were not managerial, technical, or consultancy services. As the sums were not income chargeable in India, no withholding obligation arose under Section 195 and the disallowance under Section 40(a)(ia) could not survive. Case-Laws Income Tax Thu, 21 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467810