Non-resident agents' overseas commissions are not taxed in India, exempting them from TDS u/s 195 and disallowance u/s 40(a)(i).

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....TDS u/s 195 - Since the commission has been paid to non­resident agents for services rendered outside India and the same is not chargeable to tax in India under the Act - Since there is no TDS liability, no disallowance u/s 40(a)(i) can be made.....