Export commission paid to NR not subjected to withholding of taxes as NR agent had no PE in India

IT/ILT-I : Where in transfer pricing proceedings, TPO made addition to assessee's ALP in respect of card machines sold to AEs without granting adjustments on account of payment of royalty, commission to selling agent and warranty cost, following order passed by Tribunal in assessee's own case, aforesaid adjustments as sought by assessee were to be allowed