No TDS on commission paid outside India for services received outside India by Non-Residents

Effecting deduction at source one of the aspects to be examined is whether such income is taxable in terms of Income Tax Act Brief: The commission earned by the non-resident agent who carried on the business of selling Indian goods outside India, cannot be said have deemed to be, income which has accrued and/or arisen in India & therefore no occasion to deduct tax at source in respect of the payment made to the non-resident agent arise & thus there is no liability to deduct TDS in such cases. Fact of the Case: the Assessing Officer disallowed commission paid to foreign agents of Rs. ...