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2016 (1) TMI 1279 - AT - Income TaxTDS u/s 194H - liability to deduct tax at source on the amount of guarantee commission paid to the bank - Held that:- Principal agent relationship is a sine qua non for invoking the provisions of Section 194H. While it is termed as 'guarantee commission', it is not in the nature of 'commission' as it is understood in common business parlance and in the context of the section 194H. This transaction, in our considered view, is not a transaction between principal and agent so as to attract the tax deduction requirements u/s 194H. See case of M/s. Kotak Securities Ltd. [2012 (2) TMI 77 - ITAT MUMBAI ] - Decided in favour of assessee
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