Form 15CB TDS rate if no pan of deductee

Since export commission payments to non-resident agents were not taxable in India, as agents were remaining outside, services were rendered abroad and payments were also made abroad TDS under section 195 was therefore, not deductible from payment made to NRI agents.

The AO was also of the view that the payment of commission to the foreign agents is subject to TDS u/s 195 of the Act. ... The assessee also submitted that the commission paid to the foreign agents is not chargeable to tax in India. Therefore, there was no liability to deduct the TDS u/s 195 of the Act.