TDS not deductible on business profit of non-resident in absence of PE in India

Apurva Goswami Vs DDIT (International Taxation) (ITAT Delhi) Facts- From 15CA/CB certificates filed by the assessee, the Ld. AO noted that the assessee has remitted amounts to various parties outside India without deducting tax at source. It was pointed out that the Global Business Affiliates (GBA), as per the terms and conditions of the agreement were entitled to fixed compensation and further additional commission on orders procured for the assessee. It was further stated that the nature of services as rendered by non resident agent who is carrying out business activities in other contractin...