No withholding tax on sum paid to NR for soliciting foreign customers as it's in nature of commissio

IT/ILT: Where State Bank of India issued a deposit scheme and appointed assessee as arranger for mobilizing deposits from eligible depositors and collecting bank for receiving and handling application forms and assessee, in turn, appointed sub-arrangers for rendering such services, amount paid by assessee to non-resident sub-arrangers was not a fees for managerial or technical or consultancy services and same could not be brought within ambit of FTS as per section 9(1)(vii)