Section 40(a)(ia) of the Income Tax Act, 1961 — Business Disallowance — No disallowance could be made under section 40(a)(ia) as assessee had demonstrated that all the details had specifically been filed and the assessee had filed the certificate of the CA obtained in forms of 15CA and 15CB with regard to the foreign remittance and it had filed copies of contracts with the commission agent and contracts with the exporter, thus it had given all basic details demonstrating that these agents had facilitated sales outside India and these agents had no permanent establishment in India, they were not operating from India and the commission income received by them was not taxable in India — Deputy Commissioner of income tax vs. Gujarat Ambuja Exports Ltd. [2019] 75 ITR (trib) 232(Ahmedabad)