https://www.taxtmi.com/caselaws?id=789272 Commission paid to non-resident agents for procuring export orders, where services were rendered outside India and no business connection or permanent establishment existed in India, was treated as not chargeable to tax in India. On that basis, no withholding was required under section 195, and disallowance under section 40(a)(ia) could not be made. The same legal position was applied to ocean freight payments, leading to the conclusion that the amounts were not liable to TDS and the corresponding disallowance was unsustainable. en-us Wed, 01 Apr 2026 00:00:00 +0530 Mon, 06 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789272 Commission paid to non-resident agents for procuring export orders, where services were rendered outside India and no business connection or permanent establishment existed in India, was treated as not chargeable to tax in India. On that basis, no withholding was required under section 195, and disallowance under section 40(a)(ia) could not be made. The same legal position was applied to ocean freight payments, leading to the conclusion that the amounts were not liable to TDS and the corresponding disallowance was unsustainable. Case-Laws Income Tax Wed, 01 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789272