Commission of overseas agents for marketing, procurement of orders not liable to TDS u/s 195

M/s. Evolv Clothing Company Pvt. Ltd. Vs ACIT (ITAT Chennai) Conclusion: Payment of commission to overseas agents for marketing, procurement of orders and systematic market research was not liable to TDS as the same was not liable to tax in India as per Section 9(1)(vii). Held: Assessee had paid commission to foreign agents for marketing, procurement of orders and systematic market research. AO opined that the income arising out of such payment was deemed to be taxable in India as per Section 9(1)(vii), hence provisions of Section 195 would be attracted and AO invoked the provisions of Section...