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2022 (12) TMI 692 - AT - Income TaxTDS u/s 194H - Addition on account of discount extended to prepaid distributors - assessee was required to confirm whether the figures have been shown after netting off the discount given to distributers/ franchisees and was further asked to explain whether tax at source in term of provisions of section 194H was deducted from the discount given and, if not, why the same should not be disallowed u/s 40 (a) (ia) - HELD THAT:- We find force in the contention of the Counsel. This Tribunal in A.Y.2009-10 has considered a similar quarrel [2017 (10) TMI 1093 - ITAT DELHI] As in our considered opinion disallowance made u/s. 40 (a) (ia) is not sustainable and, therefore, the AO is directed to delete the impugned disallowance. This ground is accordingly allowed. Addition on account of IUC charges paid to foreign/ non-resident telecom operators - HELD THAT:- On finding parity of facts respectfully following the decision of the Coordinate Bench A.Y. 2009-10 [2017 (10) TMI 1093 - ITAT DELHI] we direct the AO to delete the impugned disallowance. This ground is also allowed.
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