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2018 (7) TMI 1620 - AT - Income TaxTDS u/s 195 - Addition on account of non-deduction of TDS u/s 40(a) (ia) on Contract Payment and Commission - Held that:- The Hon'ble Delhi High Court in the case of EON Technology P. Ltd. (2011 (11) TMI 20 - DELHI HIGH COURT) has also taken similar view where it has been held that non-resident commission agents based outside India rendering services of procuring orders cannot be said to have a business connection in India and the commission payments to them cannot be said to have been either accrued or arisen in India. The assessee is not liable to deduct tax under the provisions of section 195 of the I.T. Act on account of foreign agency commission paid outside India for promotion of export sales outside India. Accordingly, the order of the CIT(A) is set-aside and the grounds raised by the assessee are allowed
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