Assessee claimed commission expenses in respect of commission paid to overseas agents. The AO disallowed  the expenses   for failure to deduct tax at source.  Following the decision rendered by Delhi High Court in DIT v. Panalfa Autoelektrik Ltd. (2014) 272 CTR 117 (Delhi)(HC) the ITAT observed that the overseas agent received their commission for rendering services not to the assessee in India but to the foreign buyers and if at all foreign agents are liable for making payment of income-tax, they are liable to pay the same in their own countries where they are working for gains and earned their income by way of commission from the assessee.  Accordingly the addition was deleted. (AY. 2014-15)