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2021 (10) TMI 1384 - SC ORDERTDS u/s 195 - commission paid outside India - disallowance made u/s 40(a)(i) - HC [2021 (4) TMI 93 - KARNATAKA HIGH COURT] held in the present case the Associated Enterprises has rendered services out of India in the form of placing orders with the manufacturers who are already outside India - commission was paid to Associate Enterprises out of India. No taxing event has taken place within the territories of India and therefore, the Tribunal was justified in allowing the appeal of the assessee - HELD THAT:- The special leave petition is dismissed. Pending application(s), if any, stand disposed of.
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