Amount paid to RMCs for Foreign Currency Purchase cannot be treated as Commission liable to TDS

DCIT Vs. M/s. Cox & Kings (I) Ltd. (ITAT Mumbai) Assessee has a foreign exchange division approved by the RBI and is authorized to buy foreign exchange and travelers cheques from RMCs and others and sell them to persons in need of them. RMCs are also authorized by RBI to buy foreign currency from non residents visiting various places in India. These facts would show that the RMCs are not agents of the assessee but are appointed by RBI. Though, it may be a fact that the assessee buys foreign currency from RMCs depending upon the needs, however, there is no principal agent relationship betwe...