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2019 (9) TMI 200 - BOMBAY HIGH COURTTDS u/s 194H - addition u/s 40(a)(ia) - commission involved in selling its product through SBPL - HELD THAT:- Tribunal has on facts come to the conclusion that the sale of goods to Sandu Brothers Private Limited was on principal-to-principal basis and not through an agent. Thus no amount of the discount aggregating to ₹ 7.27 crores can be classified as commission. Therefore, section 194H of the Act calling for deduction of tax of such a commission would have no application to the present facts. The Appellant has not been able to show that the finding of fact arrived at by the Revenue on the basis of the terms of the agreement is in any manner perverse, or capable of different interpretation. No substantial question of law
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