TDS liability on foreign-agent commission requires verification of payment figures and Indian taxable presence before fresh adjudication.

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....TDS-default proceedings concerning commission paid to travel agents require verification of the actual commission amount and the tax-deduction obligation on payments to foreign agents without a permanent establishment in India. Although the appellate authority treated the objections as directed at the original TDS-default order rather than the rectification order, the rectification record included the assessee's submission that tax had already been deducted on part of the commission. The Tribunal restored the matter to the Assessing Officer for fresh verification, after a final opportunity for the assessee to substantiate its commission claim, and for decision in accordance with law.....