Exemptions for Overseas Agency Fees: Section 66A of Finance Act 1994 Clarifies Non-Taxability Under POPOS and RCM Rules.

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....Services received from outside India - POPOS Rules - RCM - when such services are provided by agencies outside India these cannot be provided within India and it is for such reason that taxable services described in section 65 (105) (h) and section 65 (105) (i) of Finance Act, 1994 are within the ambit of section 66A of Finance Act, 1994 only to the extent of having been performed in India. Therefore, the commission or agency fee remitted to entities for handling of vessels outside India are exempt from taxation. - AT....