Withdrawal of Circular cannot be retrospective: TDS not deductible on Commission paid to non-resident agent Outside India

Issue- (a) Whether on the facts and in the circumstance of the case and  in  law, the Tribunal  was justified in holding that commission payments made to non­resident sales agents on which no tax was deducted is not dis allowable u/s. 40(a)(i)?

Facts of the Case and Decision of Bombay High Court

(a) For the subject Assessment Year, the Respondent ­Assessee  had  during two Assessment Years made payment of commission to non­ resident agent in respect

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