No TDS Deduction Required on US Commission Payments, Disallowance u/s 40(a)(i) Not Applicable, Appeals Dismissed.

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....Claim of deduction u/s 10A / 10AA on Disallowance made u/s 40(a)(ia) due to non deduction of TDS - Business Development Commission paid to its US based Associated Enterprises (AE) - there was no requirement on the part of the assessee to deduct TDS on such payments and accordingly, no disallowance u/s 40(a)(i) would be attracted - Since, the disallowance itself do not survive, the grounds raised in cross-appeal stand dismissed as infructuous. The assessee’s appeal stand dismissed as infructuous. - AT....