Commission paid to non-residents for services rendered abroad cannot be construed as incomes accrued or arisen in India

State Bank of India Vs ACIT (ITAT Mumbai) The discussion in the assessment order clearly points out that the expenditure has been paid towards the services in connection with the issue of RIBs and are in the nature of advertisements, collecting bank commission etc. Broadly speaking the payments are in the nature of commission paid to non-residents for services of mobilizing deposits, etc. showing that the services have been rendered abroad. It is also not the case of the AO that any of the non-residents in question have any business operation in India. Therefore, in the said background, the ra...