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In the result, the appeal filed by the Revenue is dismissed
Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad
254], which hold that such Kind of commission is not taxable in India and accordingly no liability to deduct tax was there. Further the decision of honourable Supreme Court of India in the case of CIT vs. Toshoku Limited 125 ITR 525 Still prevails as on date and is the law of the land as regards applicability of TDS provisions