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Finally in a decision rendered by the Supreme Court in Vedanta ( Bby) and MATRIX CLOTHING PVT. LTD. (Del) case [2022] 448 ITR 732 (SC) it is held that payment of export commission to foreign agents is not tax deductible. Both SLPs filed by the department stood dismissed bringing an end to this subject. 

There is a finding in this case that the services rendered were rendered outside India and that the agents were not indian residents. 

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