No TDS from sum paid to foreign agent for securing order; FA 2010 amendment to sec. 9(1)(vii) not ap

IT/ILT : Where assessee appointed foreign agents for securing export orders, Explanation added to section 9(1)(vii) by Finance Act, 2010 with effect from 1-6-1976 was not applicable in view of fact that agents had their offices situated in foreign country and they did not provide any managerial services to assessee