Commission Paid to Non-Residents for Services Rendered Outside India Not Taxable Without PE: ITAT

The ITAT ruled that commission paid to non-residents for services rendered outside India is not taxable under Indian tax law unless the non-resident has a Permanent Establishment (PE) in India. The case involved a payment made to a non-resident for services provided outside India. The tribunal clarified that such payments are not subject to Indian taxation in the absence of a PE in India. This ruling provides clarity on the taxability of cross-border commission payments and the importance of having a PE to establish tax liability in India.