Held that commission payment to foreign agents for Services rendered abroad is not liable to tax in India hence not liable to deduct tax at source. (AY.2010-11, 2011-12)
ITC Ltd v. ACIT (2024) 230 TTJ 921 / 38 NYPTTJ 626 (Kol)(Trib)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission payment to foreign agents-Services rendered abroad-Not liable to tax in India-Not liable to deduct tax at source. [S.9(1)(i), 195]
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