Section 40(a)(i) exempts TDS on sales commissions to foreign agents without permanent establishment in India for services rendered abroad.

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....Disallowance u/s 40(a)(i) - Non deduction of TDS - sales commission paid to agents outside of India, who are having no permanent establishment in India, in respect of services rendered outside of India and related to earning of income outside of India by the assessee cannot be subject to TDS under the Act. - AT....