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2014 (3) TMI 100 - AT - Income TaxDeletion of disallowance – Failure to deduct TDS on market development expenses – Held that:- The decision in Asstt. Commissioner of Income Tax Versus M/s. Hero Management Services Ltd., M/s. Hero Corporate Services Ltd. [2013 (5) TMI 730 - ITAT DELHI] followed - The Commissioner (Appeals) had correctly referred to CBDT Circular No.23J dated 23.7.1969 - where a foreign agent of an Indian exporter operates in his own country and his commission is directly remitted to him, such commission is not received by him or on his behalf in India and that such agent is not liable to Income-tax in India on the commission received by him – CIT(A) held that the appellant was not liable to deduct tax at source under section 195 of the Income-tax Act, as no income accrued or arose or deemed to accrue or arise in India - The disallowance made by the AO on account of alleged failure to deduct tax at source is set aside – Decided against Revenue.
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