Commission earned by NR agent for services rendered abroad couldn’t be taxed in India in absence of

IT/ILT : Where assessee paid commission to its foreign agents for rendering services abroad, in view of fact that those agents did not have PE in India and, moreover, services rendered were not in nature of technical service, income could not be said to accrue or arise in India and, thus, assessee was not liable to deduct tax at source while making payments to said agents