Commission paid to foreign agent not regarded as fees for technical services u/s. 9(1)(vii)

Sunbeam Lightweighting Solutions Pvt. Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that foreign commission paid by the assessee to its foreign agent for arranging of export sales and recovery of payment could not regarded as fees for technical services under section 9(1)(vii) of the Act. Accordingly, disallowance of expenditure u/s. 40(a)(i) unjustified. Facts- The assessee is engaged in the business of manufacturing of automotive die cast components, I.C. Engine parts and pistons for two wheelers and four wheelers since inception. During the relevant years the assessee had debited in P & L a...