No TDS u/s 195 on payment of buying agency commission to non-resident

M/s. Adidas India Marketing Pvt. Ltd. Vs ITO (ITAT Delhi) Conclusion: Consideration paid by assessee for services rendered by non-resident were purely in the nature of procurement services and could not be characterized as ‘managerial’, ‘technical’ or ‘consultancy’ services and thus, could not be classified as fee for technical services and accordingly, not liable for deduction of tax at source under section 195. Held: Assessee made payment of commission to ITBV on account of procurement of goods from outside India and for that purpose it had entered in a ‘buying agency agreement...