The recipients were non-residents without any permanent establishment or business connection in India....

The recipients were non-residents without any permanent establishment or business connection in India. The services were rendered outside India for which commission was paid, and the income accrued outside India. Consequently, no tax deduction at source (TDS) u/s 195 was liable to be made, and the disallowance u/s 40(a)(i) did not apply. The non-resident recipients had no presence or business activities in India, rendering their services entirely from abroad. Therefore, the assessee was not obligated to deduct TDS, and the appeal was allowed. .....

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