Withdrawal of Circular cannot be retrospective: TDS not deductible on Commission paid to non-resident agent Outside India

Issue- (a) Whether on the facts and in the circumstance of the case and  in  law, the Tribunal  was justified in holding that commission payments made to non­resident sales agents on which no tax was deducted is not dis allowable u/s. 40(a)(i)? Facts of the Case and Decision of Bombay High Court (a) For the subject Assessment Year, the Respondent ­Assessee  had  during two Assessment Years made payment of commission to non­ resident agent in respect of sales made out side India. The Assessing Officer in both the Assessment Years passed an order disallowing the payments...