The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that the TDS is required to be deductible on the amount of commission paid to overseas agents. The assessee company is engaged in the business of manufacturing and sale of engineering tools. During the relevant assessment year, the Assessing Officer made an addition against the assessee holding that TDS shall be payable on the commission to the non-resident agents considering the fact that though the payment has been made for work done outside India the profit is actually earned in India.
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