Commission payments to non-resident under exclusive procurement and supply agreement are not "fees for technical services"; section 195 TDS quashed

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....ITAT upheld that payments characterized as commission to a non-resident entity under an exclusive procurement and supply agreement do not constitute "fees for technical services" within the meaning of the Act or the India-UK DTAA, as no technical knowledge, skill or transfer was conferred to the taxpayer. Consequently, the Revenue's treatment of such commission as taxable under the fee-for-technical-services paradigm and resultant TDS liability under section 195 was found incorrect. The Tribunal set aside the impugned appellate authority's decision insofar as it upheld that characterization and quashed the corresponding TDS exigibility; the taxpayer's appeals were allowed.....