No TDS on Foreign Commission Where Income Not Chargeable in India: ITAT Agra

ACIT Vs Emco Exports (ITAT Agra) No TDS on Foreign Commission Where Income Not Chargeable in India; Section 40(a)(i) Disallowance Unsustainable – ITAT Agra The Agra Bench of the ITAT dismissed the Revenue’s appeal and upheld deletion of disallowance of ₹2.53 crore made under section 40(a)(i) for alleged failure to deduct tax under section 195 on commission paid to a foreign agent. The Tribunal noted that the assessee, an exporter of footwear, had paid commission to a non-resident agent in Italy who had no permanent establishment, office or staff in India and rendered services entirely ou...