Held that the payment of commission for services rendered by nonresidents outside India in connection with sales promotion or procuring orders for the assessee in foreign markets and the Revenue having not brought any material on record to establish that the said agents had a business connection in India within the meaning of s. 9(1)(i), or that services were rendered in India, disallowance made under s. 40(a)(i) on account of commission paid to non-resident agents without deduction of TDS is not sustainable.(AY. 2015-16)