Export Commission is not Taxable as FTS

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT), by its order dated 29 June 2026, deleted the disallowance under Section 40(a)(ia) on commission paid to a Swedish sourcing agent. 

The Tribunal held that the payments were pure export commission for services rendered outside India and not Fees for Technical Services, thereby eliminating the obligation to deduct tax under Section 195.