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No TDS Liability on Foreign Commission Payments u/s 40(a)(i) as Income Doesn't Arise in India.

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....TDS u/s 195 - disallowance u/s 40(a)(i) - commission paid to non-resident outside India for the services rendered outside India will not fall in the category of the income received or deemed to be received in India as well as accrues or arises or is deemed to accrue or arise in India. - No TDS liability - Additions deleted - AT....