ITAT rules commission paid abroad not taxable in India due to no taxable event; disallowance u/s 40(a)(i) reversed.

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....TDS u/s 195 - commission paid outside India - disallowance made under Section 40(a)(i) - the Associated Enterprises has rendered services out of India in the form of placing orders with the manufacturers who are already outside India. The commission was paid to Associate Enterprises out of India. No taxing event has taken place within the territories of India - ITAT rightly deleted the additions - HC....