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2015 (5) TMI 709 - AT - Income TaxDisallowance of export Commission u/s 40a(i) r.w.s 195 - non deduction of TDS - Held that:- The non-resident brokers have not rendered any services in India, therefore, commission income neither accrued nor arose in India in view of the decision of the. Hon'ble Delhi High Court in the case of CIT v. Eon Technology (P.) Ltd. [2011 (11) TMI 20 - DELHI HIGH COURT ]. Merely because payments have been made from India, the same cannot be made liable to be taxed in India insofar as payment was made to non-resident for the services rendered outside India as was held in the case of Dr. Reddy's Laboratory v. ITO [1995 (12) TMI 93 - ITAT HYDERABAD-A ] - Decided in favour of assessee.
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