No TDS u/s 195 for UAE Agent's Commission; Section 40(a)(ia) Addition Not Applicable.

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....TDS u/s 195 - sales promotion expenses - Addition u/s 40(a)(ia) - there is no evidence that the non-resident agent has rendered any managerial service to the assessee and the agreement indicates only services on commission basis. Accordingly, provisions of section 195 are not attracted on payment of reimbursement of expenses made to its agent in UAE. - AT....