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2019 (10) TMI 1129 - HC - Income TaxRevision u/s 263 - No deduction of tds on rendering courier services - HELD THAT:- Commissioner of Income Tax, has not appreciated the modus operandi followed by the petitioner in proper perspective and has proceeded upon the erroneous understanding that the petitioner is rendering courier services in respect of which the income therefrom would be tax deductable. The petitioner is not, in fact, a courier agency itself, but an on-board courier, that transports/carries parcels for transport from one courier agency to its counterpart in other States. For these services it receives a commission, which undisputedly, has been offered to tax. The payment received by the petitioner as freight charges represents the direct cost incurred as charges for cargo or cost of ticket purchased. Such payment constitutes a direct cost and hence would not fall within the sweep of ‘income’ upon the tax is liable to be deducted. - Decided in favour of assessee
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