https://www.taxtmi.com/highlights?id=101310 Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed. en-us Thu, 02 Jul 2026 08:07:08 +0530 Thu, 02 Jul 2026 08:07:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101310 Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed. Highlights Income Tax Thu, 02 Jul 2026 08:07:08 +0530 https://www.taxtmi.com/highlights?id=101310