ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA
In the result, revenue’s appeal stands dismissed
ITA 415/AGR/2025[2020-21]Status: DisposedITAT Agra15 Jan 2026AY 2020-21
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21
Section 195Section 250Section 40Section 9
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
