Law on dedutibility of TDS on commission paid by Indian entity to foreign agents

ACIT Vs. Manufax (India) S.B. (ITAT Agra) This is Department’s appeal for assessment year 2010-11. The effective grounds are as follows: “1. That the Ld. CIT(A)-1, Agra has erred in law and on facts in deleting the addition of Rs.36,30,862/- made u/s 40(a)(i) on account of non-deduction of tax on payments of commission to non-resident/foreign commission agents ignoring the facts that commission paid foreign commission agents is deemed to accrue or arise in India, which required deduction of tax as per section 195 of the I.T.Act.. 2. That the Ld. CIT(A)-1 ,Agra has erred in law and facts i...