Nonresident Agent Commissions Not Taxable in India: Section 40(a)(i) Exemption Explained, Section 9 Not Triggered.

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....Disallowance u/s 40(a)(i) - TDS - commission payments to the nonresident agents are not taxable in India, as the agents are remaining outside, services are rendered abroad and payments are also made abroad.. When the transaction does not atract the provisions of Section 9 of the Act, then there is no question of applying Explanation 4 to Section 9 - HC....