TDS u/s 195 not deductible on commission paid to foreign agents for procurement of orders

ACIT Vs Alnoor Exports (ITAT Delhi) ITAT Delhi held that commission paid to foreign agents for procurement of orders do not fall under Technical, Managerial or consultancy services. Accordingly, TDS not deductible on commission paid to such foreign agents. Facts- The Assessing Officer while completing the assessment noticed that the assessee debited commission expenses of Rs.80,32,863/- in P & L account of export sales. AO disallowed commission expenses to foreign agents for non-deduction of TDS u/s. 195 of the Act. CIT(A) deleted the disallowance. Conclusion- Held that the assessee was no...