Allowing the appeal of the assessee where assessee had paid commission to non-resident entities for sales services rendered by them wholly outside India not liable to deduct tax at source. (AY. 2014-15, 2015-16)
Modern Threads India Ltd. v. ACIT (2021) 187 ITD 815 / 211 TTJ 1 (UO) (Jaipur)(Trib.)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Commission to non-resident entities-Services rendered outside India-Not liable to deduct tax at source-Article 7 of the OECD Model Convention. [S.195]