Disallowance U/s. 40(a)(i) on commission to foreign agents paid outside India

Eaton Industrial Systems (P) Ltd. Vs DCIT (ITAT Pune) Where assessee-company paid sales commission foreign of agents for securing export orders from the buyers abroad the services were not rendered by such foreign agents in India, and no part of the said income had arisen in India, therefore, TDS was not required to be deductible at source, so as to warrant disallowance under section 40(a)(i). FULL TEXT OF THE ITAT JUDGMENT  The appeal filed by the assessee is against order of DCIT, Circle-8, Pune, dated 31.12.2013 relating to assessment year 2009-10 passed under section 143(3) r.w.s. 144C(1...