Export Commission Disallowance u/s 40(a)(i) Challenged: Non-Resident Agents Without PE in India Exempt from TDS Requirement.

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....TDS u/s 195 - disallowance made u/s 40(a)(i) - export commission paid to overseas agents, who arrange for exports and procure export orders for the assessee - the said non-resident agents do not have any PE in India and that they are domiciled in U.K and USA - the provisions of section 195(2) of the Act would not come into operation at all. - AT....