https://www.taxtmi.com/caselaws?id=794248 A rectification under section 154 that only corrects an inadvertent omission and does not enhance tax liability can be made without fresh notice to the assessee; the challenge to the rectification therefore failed. Commission paid to an overseas agent for procuring export orders, conveying buyer requirements and following up payments was not shown to be technical or consultancy service, and in the absence of evidence of any such service or a proved written agreement, it was treated as business commission rendered outside India. The payment was not fees for technical services, so TDS was not attracted and disallowance under section 40(a)(ia) failed on merits. en-us Mon, 29 Jun 2026 00:00:00 +0530 Thu, 02 Jul 2026 08:07:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794248 A rectification under section 154 that only corrects an inadvertent omission and does not enhance tax liability can be made without fresh notice to the assessee; the challenge to the rectification therefore failed. Commission paid to an overseas agent for procuring export orders, conveying buyer requirements and following up payments was not shown to be technical or consultancy service, and in the absence of evidence of any such service or a proved written agreement, it was treated as business commission rendered outside India. The payment was not fees for technical services, so TDS was not attracted and disallowance under section 40(a)(ia) failed on merits. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794248