No TDS on commission paid to NR agents

No TDS on commission paid to NR agents for services rendered outside India in absence of their PE in India

IT/ILT : Sales commission paid by assessee to non-resident commission agents for services rendered by them outside India was not chargeable to tax in India as commission agents did not have a permanent establishment in India, hence not liable to TDS

IT/ILT : Where assessee had not earned profit from occasional shipping and was not a non-resident, section 172 did not have application in relation to assessee

 [2015] 56 taxmann.com 265 (Panaji - Trib.) IN THE ITAT PANAJI BENCH Assistant Commissioner of Income-tax, Circle-1 (1), Panaji v. Karishma Global Mineral (P.) Ltd.