Foreign Entity Commission Exempt from Tax Deduction in India u/s 195; No Permanent Establishment Requirement Met.

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....TDS u/s 195 - Commission paid - when undisputedly TEI is not having any Permanent Establishment (PE) in India the income of TEI received as commission from assessee company was not chargeable to tax in India as the same was neither accrued in India nor received in India and as such was not required to deduct tax at source u/s 195 of the Act. - AT....