Commission to foreign agents not taxable in India: ITAT rules TDS not applicable

The ITAT ruled that commission payments to non-resident agents for services rendered outside India are not taxable in India and thus not subject to TDS. The Tribunal relied on settled judicial precedents affirming that income must accrue or arise in India to attract taxation. The decision provides clarity for exporters engaging foreign intermediaries and underscores India’s adherence to territorial taxation principles under Section 9 of the Income Tax Act.