https://www.taxtmi.com/caselaws?id=797956 Commission paid to non-resident agents for procuring export orders is not chargeable to tax in India where the agents render all services outside India and have no permanent establishment or business operations in India. The connection between the commission and export orders executed by an Indian payer does not, by itself, cause the income to accrue or arise in India. Since tax deduction at source applies only to payments chargeable to tax in India, no withholding obligation arose on the foreign-agent commission, and the related disallowance was deleted. en-us Mon, 24 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 08:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797956 Commission paid to non-resident agents for procuring export orders is not chargeable to tax in India where the agents render all services outside India and have no permanent establishment or business operations in India. The connection between the commission and export orders executed by an Indian payer does not, by itself, cause the income to accrue or arise in India. Since tax deduction at source applies only to payments chargeable to tax in India, no withholding obligation arose on the foreign-agent commission, and the related disallowance was deleted. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797956