Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21
199 of the Act implies that only the recipient of the sum i.e., payee would seek a refund. In view of the above, hence, no tax is deductible under section 195 of the Act on commission payments and consequently the expenditure on export commission payable to non-resident for services rendered outside India becomes allowable expenditure and the same