1. The applicant which is an Indian Company and is engaged in the business of manufacture and supply of industrial pesticides has filed this application for advance ruling seeking determination of the non-resident’s tax liability under the Income-tax Act in connection with the proposed transactions with the non-resident Company by name Zaikog Trading Co. (hereafter referred to as ‘Zaikog’) is a company incorporated in the Republic of South Africa and it is in the business of promotion and distribution of various products. Zaikog has offered its services to promote and market the product known as ‘Imida Chloprid formulation for termite control’. For the services rendered by it, Zaikog will receive from the applicant a commission of 3 per cent or a mutually agreed percentage on every completed transaction. In the application, it is broadly stated that the role of Zaikog is to communicate the details of the interested parties to the applicant who will pursue the proposal for confirmed orders. Such confirmed orders will be executed directly by the applicant. The sale consideration will be received in India by the applicant. The amount of commission payable to Zaikog is paid from