TDS u/s 195 on commission paid to overseas agents?

DCIT (OSD) Vs Jay Chemical Industries Ltd. (ITAT Ahmedabad) Conclusion: Commission paid to non-resident agent was not liable to tax under the provisions of act when the services were rendered outside India, payments were made outside India and there was no permanent establishment or business connection in India, therefore, assessee was not required to deduct TDS u/s 195(2). Held: Assessee had claimed commission payment to various non-residents on export sales made during the year under consideration. AO had disallowed the commission paid to foreign agents by holding that the income arising on ...