Assessee made payment of commission to one IIBL, a non-resident, for agency services rendered by it for the execution of sale and its allied activities of garments in Bangladesh. Assessing Officer held that the assessee was liable to deduct TDS on said remittance made to IIBL. CIT(A) affirmed the order of the Assessing Officer. On appeal, the Tribunal held that   IIBL carried out its activities outside India and income earned by it was not taxable in India. Payment made to a foreign agent was also not on account of royalty or fees for technical services; therefore, no tax was to be deducted at source under section 195 on such payment made to IIBL.  (AY. 2013-14, 2014-15)