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2017 (4) TMI 1363 - HC - Income TaxTDS u/s 194H or u/s 194J - payment made to various mil societies on account of milk price difference - TDS liability - Services Charges the RCDF - Held that:- As decided in assessee's own case [2015 (7) TMI 1074 - ITAT JAIPUR]as far as assessee's business is concerned, there is no rendering of any managerial services by RCDF as alleged by the AO u/s 194H and upheld ld. CIT(A) u/s 194J. Since there is no rendering of any services and the payment is not made for any managerial services to RCDF, therefore, payment can neither be held as liable for TDS u/s 194H of the Act as commission/brokerage as held by the AO nor u/s 194J for rendering any managerial services as held by the ld. CIT(A). In view thereof, we hold that assessee's impugned payment to RCDF are not liable for TDS. This ground of the assessee is allowed.
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