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 deduc

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