K.H. a Partnership firm, carries on export business. A party in Thailand
procures orders form its customers and forward the same to K.H. in Kolkata.
K.H. exports the goods directly to the buyers and receives the sale proceeds
from them in India. The party in Thailand canvases and procures the orders,
has to be paid Commission. K.H. desires to remit the same within the R.B.I.
Norms through official channels. Since all activities are done outside India
and none in India, Commssion payable to the party accrues and arises and
will be received by the party in Thailand. K.H. does not have any P.E. outside
India.
On the above facts does the case require to deduct any tax U/s 195 of the
Act?