Dismissing the appeal of the Revenue the Court held that the Commission paid to foreign agents on export of goods, services were rendered out side India as the recipient is not liable to tax in India the assessee is not liable to deduct tax at source. No disallowance can be made. Order of Tribunal is affirmed. (AY. 2012-13)
PCIT v. Shantilal Khushaldas and Brothers Pvt. Ltd. (2024) 470 ITR 73 (Bom) (HC)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Business expenditure-Commission paid to foreign agents on export of goods-Services rendered out side India-Not liable to tax in India-Not liable to deduct tax at source-No disallowance can be made [S. 9(1)(i), 37(1), 195, 260A]
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