Assessee-company being into export business paid certain amount of commission to TEI, Japan for procuring order for supplying, installing and successful commissioning of cold rolling mill to a Kenyan company. The Assessing Officer disallowed the amount for failure to deduct tax at source.   Commissioner (Appeals) affirmed the order of the Assessing Officer. On appeal the Tribunal held that mere rendering of service of procurement of export orders by a non-resident company for Indian company does not fall in category of managerial/consultancy services as explained in Explanation 2 to section 9(1)(vii). Accordingly-disallowance made under section 40(a)(i) of commission paid by assessee was unjustified.  (AY. 2016-17)