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Circular No. 786-Income Tax Deduction of tax u/s 195 and the taxability of export commission payable to non-resident agents rendering services abroad – clarification regarding. In the Audit Report for 1997-98 (D P No 79(I.T.) The Comptroller & Auditor General (C&AG) raised an objection that the Assessing Officer in computing the Profits and Gains of Business or Profession, in a case in Mumbai charge, had wrongly allowed a deduction in respect of a payment to a non-resident where tax had not been deducted at source.