No TDS on Foreign Agent Commission for Services Rendered Abroad; ITAT Deletes Section 40(a)(i) Disallowance

Kiri Industries Ltd. Vs DCIT (ITAT Ahmedabad) The appeal was filed by the assessee against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi for Assessment Year 2021–22. The assessee raised multiple grounds challenging disallowances made by the Assessing Officer and confirmed by the CIT(A), including export commission payments, interest expenditure, and employees’ contribution to PF/ESI. During assessment proceedings under sections 143(3) and 144B of the Income-tax Act, the Assessing Officer made three primary disallowances. First, commiss...