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TMI Blog2020 (7) TMI 156X X X X Extracts X X X X X X X X Extracts X X X X ..... o same. Tribunal examined the issue in the light of agreement and material on record and found that the agent had their base situated in Abroad and moreover services were also rendered by them outside. Therefore, assessee is not required to deduct tax at source while making payments in question. A.O. in the assessment order has also made disallowance since in earlier year also of the same issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... heard the Learned Representatives of both the parties through video conferencing and perused the material on record. 3. The A.O. on perusal of Schedule-18 of of Selling Expenses noticed that assessee had debited expenses in the name of commission to non-resident other than a company or a foreign company amounting to ₹ 13,67,739/-. The A.O. took-up the issue of TDS made on such payments t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder : Where assessee-firm made payments of commission to those agents, since those agents had their offices situated abroad and, moreover, services were also rendered by them outside India, assessee was not required to deduct tax at source while making payments in question. 4.1. Learned Counsel for the Assessee submitted that facts are identical as have already been considered in earlier ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies are also same. The Tribunal examined the issue in the light of agreement and material on record and found that the agent had their base situated in Abroad and moreover services were also rendered by them outside. Therefore, assessee is not required to deduct tax at source while making payments in question. The A.O. in the assessment order has also made disallowance since in earlier year also o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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