2014 (5) TMI 1128

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....JCIT Respondent by : Shri G. Seetharaman, CA O R D E R PER Dr.O.K.NARAYANAN, VICE-PRESIDENT This appeal filed by the Revenue relates to assessment year 2010-11. The appeal is directed against the order of the Commissioner of Income Tax (Appeals)-IV at Chennai, passed on 5.9.2013 and arises out of the assessment completed under Section 143(3) of the Income-tax Act, 1961. 2. The only ....

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....non-resident agents are carrying on the business wholly outside India. The assessee had paid commission to those non-resident agents for services rendered by them wholly outside India. It also has to be seen that the nonresident agents did not have any permanent establishment (PE) in India. The commissions were remitted by the assessee directly to the non-residents outside India. 6. In the fact....