Held that there was no dispute that the services for which commission was paid by the assessee were rendered by non-resident agents outside India for procuring export orders from customers outside India. The payments were made outside India and the non-residents did not have any geographical or permanent establishment in India. From the terms of the agreement, it was noted that the nature of services rendered by non-resident agents was for procuring export orders of products of the assessee, and the payments made by the assessee to them were like commission which was specifically mentioned in the agreement. The Tribunal upheld the order of the Commissioner (Appeals). (AY. 2016-17)