Commission Payment Claim Denied Due to TDS Liability; Non-Resident Agents' Earnings Deemed Business Profits, Not Taxable in India.

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....Disallowance of claim of commission payment - Liability to deduct TDS for making payment to Non-Residents - withholding tax - where payment of commission has been made by the assessee to non-resident agents for rendering services of procuring sales order etc. it was not FTS but business profit and in absence of PE of such agents in India, such commission payment was not taxable in India. - AT....