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2016 (4) TMI 418 - ITAT JAIPUR

2016 (4) TMI 418 - ITAT JAIPUR - TMI - TDS u/s 194H - payment of cess made to RCDF is in the nature of technical and professional service - charging interest U/s 201(1A) - Held that:- Payment to RCDF cess, it has not been demonstrated by the Department that any managerial services in this connection have been rendered to assessee by RCDF qua this amount. RCDF is an apex cooperative body and cess is paid to it by virtue of federal structure in Rajasthan cooperative set up. Thus as far as assessee .....

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sion charges and audit fees liable to be deducted TDS - Held that:- The conversion charges were paid on cost to cost basis and no profit has been charged as claimed by the assessee. When there is no element of profit, the TDS provisions are not applicable. The case law referred by the assessee i.e. ITO Vs. Dr. Willmar Schwabe India (P) Ltd. (2005 (3) TMI 398 - ITAT DELHI-D ) is squarely applicable. Therefore, we delete the addition confirmed by the ld CIT(A) under the head conversion charges. Au .....

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2 - SUPREME COURT OF INDIA ] then no interest is to be charged from the assessee U/s 201(1A) as the assessee claimed that on legal fees Shri Bharat Vyas, advocate had paid tax already by disclosing this income being nominal amount of interest, therefore, we delete the addition confirmed by the ld CIT(A).- Decided in favour of assessee

Non deducting TCS - demand U/s 206C(6A) and levy of interest U/s 206C(7) - Held that:- As per this definition, the item sold by the assessee in scrap i. .....

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o amount has been paid in form of commission or brokerage. The case laws referred by the assessee are squarely applicable, therefore, we uphold the order of the ld CIT(A).- Decided in favour of assessee

Non deducting TDS U/s 194H on payment of milk purchase price difference to milk societies - disallowance U/s 40(a)(ia) - Held that:- The assessee purchased milk from the primary society not from the cattle owners. The payments are made to the primary society. The price of the milk is d .....

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rchase difference is cost of goods purchased. By respectfully following the Coordinate Bench decision in assessee’s own case for A.Y. 2008-09 we hold that the assessee is not liable to deduction TDS U/s 194H of the Act - Decided in favour of assessee - ITA Nos. 82 to 86/JP/2015, ITA Nos. 104 to 108/JP/2015, ITA No. 87/JP/2015, ITA No. 96/JP/2015 - Dated:- 4-3-2016 - SHRI R.P. TOLANI, JM & SHRI T.R. MEENA, AM For The Assessee : Shri P.C. Parwal (CA) For The Revenue : Shri Raj Mehra (JCIT) O .....

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.Y. 2006-07) (Assessee s appeal) 1 The Ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that payment of cess made to RCDF is in the nature of technical and professional service and thereby confirming the levy of interest u/s 201(1A) at ₹ 10,268/-. He has further erred in confirming the levy of interest u/s 201(1A) even when RCDF has paid tax more than that due as per return and there is no loss of interest to the Revenue. .....

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unds of ITA No. 83/JP/2015 (A.Y. 2007-08) (Assessee s appeal) 1. The Ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that payment of cess made to RCDF is in the nature of technical and professional service and thereby confirming the levy of interest u/s 201(1A) at ₹ 11,240/-. He has further erred in confirming the levy of interest u/s 201(1A) even when RCDF has paid tax more than that due as per return and there is no los .....

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r return and there is no loss of interest to the Revenue. 3. The ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that Tax is to be collected at source in respect of sale of scrap and thereby confirming the demand of tax of ₹ 1,423/- u/s 206C(6A) and interest ₹ 854/- u/s 206C(7). He has further erred in confirming the levy of interest u/s 206C(7) even when the payee has paid tax more than that due as per return and t .....

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e than that due as per return and there is no loss of interest to the Revenue. 2. The ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that Tax is to be deducted at source in respect of conversion charges and thereby confirming the levy of interest of ₹ 3,332/- u/s 201(1A). He has further erred in confirming the levy of interest u/s 201(1 A) even when the payee has paid tax more than that due as per return and there is no .....

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st to the Revenue. 4. The ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in not giving any decision regarding the action of the AO in holding that purchase of printed banners and iron frame is a contract for advertisement covered u/s 194C and thereby levying tax of ₹ 503/- u/s 201(1 A) and interest of ₹ 480 u/s 201(1A) on account of non deduction of tax at source on such purchase. He has further erred in confirming the levy of interest u/s 201 (1A) even when t .....

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vy of interest u/s 201(1 A) even when RCDF has paid tax more than that due as per return and there is no loss of interest to the Revenue. 2. The Id. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that Tax is to be deducted at source in respect of conversion charges and thereby confirming the levy of interest of ₹ 4,240/- u/s 201(1A). He has further erred in confirming the levy of interest u/s 201(1A) even when the payee has .....

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an that due as per return and there is no loss of interest to the Revenue. Grounds of ITA No. 86/JP/2015 (A.Y. 2010-11) (Assessee s appeal) 1. The Id. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of the AO in holding that Tax is to be deducted at source in respect of conversion charges and thereby confirming the levy of interest of ₹ 2,220/- u/s 201(1A). He has further erred in confirming the levy of interest u/s 201(1A) even when the payee ha .....

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e than that due as per return and there is no loss of interest to the Revenue. Grounds of ITA No. 87/JP/2015 (A.Y. 2011-12) (Assessee s appeal) 1. The Ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the action of AO in holding that payment of milk purchase price difference to milk societies (DCS & PDCS) is payment of commission/brokerage liable for deduction of tax at source u/s 194H which the assessee has failed to declare and thereby confirming the disa .....

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Whether on facts and in law, Ld. CIT(A) erred in holding that the margin of distribution in the payments made by the assessee to its distributors is not commission liable for deduction u/s 194H of the Income-tax Act, 1961? 2. Whether on facts and in law, Ld. CIT(A) erred in holding that the assessee was not liable to pay interest u/s 201(1A) of the Income-Tax Act, 1961 as there was no tax liability on the income of the deductee ? Ground of ITA No. 96/JP/2015 (A.Y. 2011-12) (Revenue s appeal) On .....

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the nature of technical and professional service and levy of interest U/s 201(1A) of the Income Tax Act, 1961 (in short the Act) at ₹ 10,268/- in A.Y. 2006-07, ₹ 11,240/- in A.Y. 2007-08, ₹ 23,329/- in A.Y. 2008-09, ₹ 30,771/- in A.Y. 2009-10 and ₹ 2,220/- in A.Y. 2010-11. The assessee is a Cooperative Society, which collects milk from village level primary societies, which is engaged in the processing of milk and marketing milk and milk products to their member uni .....

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ments made by the assessee. The assessee replied vide letter dated 22/1/2011, which has been reproduced by the ACIT(TDS) on page No. 5 to 27 of the assessment order. The ld Assessing Officer observed that the assessee made payment of Cess to RCDF U/s 194J from F.Y. 2005-06 to 2009-10. The assessee claimed before the Assessing Officer that it is reimbursement of expenditure but the assessee could not clarify particulars of expenditure for which reimbursement had made before the Assessing Officer. .....

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ieu of the professional/technical services covered U/s 194J of the Act, which is liable to deduct TDS. Accordingly, the ld Assessing Officer held that the assessee defaulted U/s 201(1) in respect of such tax which ought to have been deducted thereon and interest U/s 201(1A) is also charged. However, as the payees had paid due tax on such receipts/income, therefore, keeping in view the decision of Hon ble Apex Court in the case of Hindustan Coca Cola Beverages Pvt. Ltd., no demand was raised U/s .....

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t on account of cess payment to M/s RCDF1but the appellant in the ground of appeal has objected only to the raising of demand on account of interest u/s 201(1 A) of IT Act because of the fact that the AO though held the assessee to be assessee in default for non deduction of TDS u/s 194J but did not raise the demand u/s 201(1) of IT Act as the payee has paid due taxes. However the issue of charging of interest u/s 201(1A) of IT Act is closely related with the issue of applicability of provisions .....

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RCDF provided expert professional guidance and services to the assessee for which such payment of cess was made. On the other hand the appellant case is that such payment was basically on account of reimbursement of expenses incurred by M/s RCDF on behalf of the assessee. However as noted by the AO there in nothing on record which may indicate that any expenditure was incurred by M/s RCDF on behalf of the assessee. The facts available on record indicate that the appellant has availed technical a .....

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ollowing case laws: (i) CIT Vs. Eli Lilly & Company (I) Pvt. Ltd. (312ITR 225) (SC) (ii) Hindustan Coca Cola Beverage Ltd. Vs. CIT, 293 ITR 163 (SC) (iii) ITO, W-TDS-2, Jaipur Vs. M/s Vodafone Essar Digilink Ltd. (iv) ITA No.239/JPR/2012, ITAs No. 250 to 252/JPR/2012 (ITAT Jaipur) Keeping in view the facts and circumstances discussed above as also placing reliance on the case laws referred above the action of the AO in charging of interest u/s 201(1A) is confirmed. 4. Now the assessee is app .....

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payment to RCDF cess, it has not been demonstrated by the Department that any managerial services in this connection have been rendered to assessee by RCDF qua this amount. RCDF is an apex cooperative body and cess is paid to it by virtue of federal structure in Rajasthan cooperative set up. Thus 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 Id. C1T(A) u/s 194J. Since there is no rendering of any .....

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he ld AR. 6. We have heard the rival contentions of both the parties and perused the material available on the record. The facts and nature of payment are identical to A.Y. 2008-09 and the Coordinate Bench had decided that the payments were not made for any managerial service to RCDF. Therefore, payment cannot be held the lower authorities. By respectfully following the decision of the Coordinate Bench in assessee s own case for A.Y. 2008-09, we allow the assessee s appeal on this ground in all .....

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o be deducted TDS U/s 194C and 194J of the Act respectively. The conversion charges paid by the assessee on which TDS is liable to be deducted and interest U/s 201(1A) is calculated as under:- The audit fees and reimbursement expenses are liable to be deducted TDS as per Assessing Officer as under:- A.Y. Amount 201(1A) Audit Fees Reimbursement of expenses 2006-07 27600 8988 228 2007-08 27600 20202 241 8. Being aggrieved by the order of the Assessing Officer, the assessee carried the matter befor .....

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rofit is given. The TDS was to be deducted, the ld CIT(A) has held that the assessee had conducted some specific work of conversion of milk into ghee and milk powder as per his own specification. It is also a fact that the milk was provided by the assessee, therefore, he held these payments as contractual in nature and also is liable for TDS. 8.1 For legal fees, it has been held that the assessee is liable to deduct TDS in A.Y. 2006-07 and 2007-08 as audit fees was paid @ ₹ 2300 per month .....

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rocessed by district level societies. To make available the milk at all places, surplus milk from one union to another transferred or some time milk is processed to make the milk powder or ghee. All these transfer activities from one union to another is done on cost to cost basis without adding any profit margin or rather the actual cost incurred by other milk union is just reimbursed without giving any profit. The assessee has reimbursed only actual cost incurred by these milk unions. Thus when .....

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nt is made will make any material difference. However, it is ignored that when there is no income given, it is a case of simple reimbursement of expenses on which provision of Chapter XVII-B is not applicable. Hence, is not liable for deduction of tax at source on conversion charges. 9.1 He further submitted that an audit fee is paid to G.M. Gupta & Co. for monthly internal audit. Payment made to it is @ ₹ 2,300/- p.m. Since the monthly payment is below ₹ 20,000/-, no tax is dedu .....

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Advocate to whom payment is made has paid due taxes on such amount. If he has paid that tax, demand u/s 201(1) be reduced but interest u/s 201(1A) be charged. It is submitted that when the recipient has paid the tax on the legal fees paid to him and there is no loss of revenue to the department, no interest u/s 201(1 A) be levied. In view of above, the interest levied u/s 201(1 A) is uncalled for and be deleted. 10. At the outset, the ld DR has vehemently supported the order of the ld CIT(A). 11 .....

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n charges. Audit fees is also paid on monthly basis to G.M. Gupta & Company, which is also below ₹ 20,000/- as well as also below the specified limit as per the TDS provisions, therefore, the same is not liable to be deducted TDS. Interest on TDS deductible on legal fees paid to Shri Bharat Vyas has been set aside by the ld CIT(A) for verification, if the recipient has paid advance tax and fulfill the condition of Hon'ble Supreme Court decision of Hindustan Coca Cola Beverages Pvt. .....

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#8377; 503 in A.Y. 2008-09, ₹ 304/- in A.Y. 2009-10 and ₹ 752/- in A.Y. 2010-11. The ld Assessing Officer has observed as under:- F.Y. Sales amount TCS Delay (In month) Demand U/s 206C Interest 206C Total 2006-07 142252 1423 60 1423 854 2277 2007-08 104826 1048 48 1048 503 1551 2008-09 84540 845 36 845 304 1149 2009-10 313883 3139 24 3139 753 3892 The ld Assessing Officer further observed that the assessee sold scrap during the year under consideration, which is liable for TCS U/s 20 .....

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essee sold scrap and is covered U/s 206 of the Act. 13. Being aggrieved by the order of the Assessing Officer, the assessee carried the matter before the ld CIT(A), who had dismissed the ground of appeal by observing as under:- The assessee has sold some scraps items and as per A.O. TCS was to be made U/s 206C of IT Act. On the other hand the appellant case is that provisions of Sec. 206C will be applicable only in respect of that scraps which is originated from manufacturing or mechanical worki .....

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the action of the Assessing Officer is confirmed. 14. Now the assessee is appeals before us. The ld AR of the assessee has submitted that the assessee sold scrap material like, tin, polythene, iron scrap, plastic drum, etc. The ld Assessing Officer held that scrap materials are part of manufacturing process and would constitute scrap as defined u/s 206C of the Act. Accordingly, he treated the assessee as assessee in default u/s 206C(6A) and raised a demand u/s 206C(6A) and u/s 206C(7). CIT(A) co .....

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ated during the manufacturing or mechanical working of material. The assessee is processing milk and selling the same to customers in Saras Brand . None of these scrap are generated during the manufacturing or mechanical process of material. Hence provision of section 206C is not applicable in the present case. The CBDT Circular only clarifies that even trader of scrap are liable for TCS. Therefore, this circular is not applicable. In view of above, the demand u/s 206C(6A)& u/s 206C(7) is un .....

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the item sold by the assessee in scrap i.e. Tin, iron scrap, plastic drum etc. is not scrap generated from manufacturing process. Therefore, it is not liable to be deducted TCS U/s 206C of the Act. Accordingly, on this ground, the assessee s appeal is allowed. 17. Ground No. 4 of the assessee s appeal for A.Y. 2008-09 is against interest on TDS U/s 194C of the Act, advertisement expenses at ₹ 503 in A.Y. 2008-09. The ld Assessing Officer observed that the assessee purchased printed banner .....

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considering the finding of both the lower authorities, we do not find any merit in the case of revenue that such payments are covered U/s 194C. Being a nominal amount and finding given by the lower authorities, we delete the addition confirmed by the ld CIT(A). 18. Now we take revenue s appeals. Regarding revenue s appeal from A.Y. 2006-07 to 2010-11, the ld Assessing Officer observed that the assessee being in the dairy marketing through diary cooperative societies, it fixes MRP price of milk .....

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icer that Section 194H is applicable where brokerage or commission was paid to the distributor. The assessee entered into an agreement between various distributors on principal to principal basis and that the transaction with the distributor was for purchase and sale of goods for a price paid or promised to be paid. As per agreement, the risk and reward relating to milk and other product were transferred to the distributor and the assessee was not responsible for losses relating to transit loss, .....

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laimed refund also. He relied on the decision in the case of Hindustan Coca Cola Beverages Pvt. Ltd. Vs. CIT (Supra). However, the ld Assessing Officer not convinced with the submission of the assessee but calculated the interest U/s 201(1A) of the Act on TDS deductible from A.Y. 2006-07 to 2010-11, which was challenged by the assessee before the ld CIT(A) in appeal. The ld CIT(A) after considering the assessee s reply as well as case laws referred on identical issue by the assessee i.e. ACIT (T .....

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19. Now the revenue is in appeals before us. The ld DR has vehemently supported the order of the Assessing Officer. At the outset, the ld AR of the assessee has argued that the issue is identical to Ajmer Zila Dugdh Utpadak Sangh Limited Vs. ITO 30 DTR 418 and ACIT (TDS) Vs M/s Jaipur Zila Dugdh Utpadak Sahakari Sangh Limited (supra) wherein the Hon ble ITAT has decided that any sale of milk by the assessee to the distributor is sale agreement on principal to principal basis and not liable for d .....

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against the addition made U/s 40(a)(ia) of the Act. 20. We have heard the rival contentions of both the parties and perused the material available on the record. The identical issue has been considered by the Coordinate Bench in various cases as submitted by the assessee. The assessee s transaction with distributor is sale. The risk and reward is with the distributor. The transaction is principal to principal basis. The distributor is not agent of the assessee. From the side of assessee, no amo .....

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to milk societies and disallowance U/s 40(a)(ia) of the Act. The ld Assessing Officer observed that the assessee is a Cooperative Society engaged in manufacturing and trading of milk and milk product etc. The assessee had claimed expenditure of ₹ 1,32,22,045/- on account of milk purchase price difference. He further held that these payments were in the nature of commission/brokerage and was liable for deduction of TDS but the assessee has not deducted TDS. Therefore, he disallowed U/s 40( .....

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through these societies/samitis. The assessee has been paying 3% on cost of the purchase made from the cattle owners as a commission of brokerage, which is also part of sale amount. The appellant also argued before the ld CIT(A) that even if addition U/s 40(a)(ia) of the Act is to be made, such disallowance should be with reference to the amount, which was payable and if the amount already been paid then no such disallowance can be made U/s 40(a)(ia) of the Act, for which he relied on the decisi .....

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a circular No. 10/DV/2013, F. No. 279/Misc./M-61/2012-ITJ(Vol-II) on Section 40(a)(ia) of the Act and clarified that disallowance U/s 40(a)(ia) is to be made not only on payable but paid amount. He further considered the Hon'ble Supreme Court decision in the case of CIT Vs/ Hero Cycles P. Ltd. (1997) 228 ITR 463 wherein it has been held that the circular issued by the Board is binding on ITO not on appellate authority or Tribunal or Court or even the assessee. Keeping in view of these facts, .....

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.e. revenue and assessee are in appeals before us. The ld AR of the assessee has submitted that the assessee is a cooperative society. It was constituted to give momentum to cooperative movement in milk sector and to push the white revolution in country through dairy cooperatives. The diary cooperative follow vertical integrated three tier structure as under: - Primary Society i.e. village Diary Co-operative at the bottom - Union i.e. District processing union at the middle level - Federal Socie .....

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f milk is based on the fat and SNF content in the milk. Collected milk is tested and processed in the plant of the assessee. On the basis of quality of the milk, the amount payable to the primary society against the cost of the milk is determined. To this cost 3% is added as milk purchase price difference against the margin of the primary societies. This amount alongwith the cost of the milk is paid to the primary societies. In the books of account the cost of the milk is debited under the head .....

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heir charges. This charge is a procurement cost to the assessee and not a payment of commission to them as the relationship between the assessee and the primary society is on principal to principal basis and not on principal agent basis. He has further drawn our attention on definition of sales as per the VAT Act, 2003 and argued that the commission is paid to a person when he acts on behalf of the other person. In such a case, the payment for value of the goods or service is made directly to th .....

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ieties purchased milk from cattle owners. The payment made to the cattle owner is not concerned of the assessee. Thus the payment made to the primary society is not a commission covered U/s 194H of the Act. The ld Assessing Officer relied on the decision of CIT(A) in A.Y. 2008-09, which was decided against the assessee. The Hon ble ITAT, Jaipur Bench had decided this issue in ITA No. 277/JP/2013 for A.Y. 2008-09 in assessee s own case vide order dated 21/7/2015. The ld AR has drawn our attention .....

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ed that if no TDS is deducted U/s 194H, paid and payable aspect is to be examined. The assessee claimed that there was no amount payable during the year under consideration to the primary society, for he relied on the decisions in the case of CIT Vs. Vector Shipping Services (P) Ltd. (supra), DCIT Vs. Ananda Marakala (2014) 150 ITD 323 (Bang.)(Trib) and ITO Vs. M/s Theekathir Press (Chennai) (Trib) ITA No. 2076/(Mds)/2012 dated 18/09/2013. It is further argued that if two opinions have been expr .....

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