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Section 194B is described as applying the TDS threshold to each individual payment of online-game winnings, rather than to aggregated wallet balances, under the version applicable to the relevant year. The discussion notes that later statutory amendments introducing aggregation, followed by a single-transaction standard, do not expand the earlier provision. It further explains that section 40(a)(ia) disallows otherwise deductible expenditure and cannot apply where player payouts were neither debited to the Profit and Loss Account nor claimed as deductions. Payments for advertising-platform access to a non-resident are discussed as not constituting royalty or fees for technical services, following an earlier coordinate-Bench approach.
Section 194B is described as applying the TDS threshold to each individual payment of online-game winnings, rather than to aggregated wallet balances, under the version applicable to the relevant year. The discussion notes that later statutory amendments introducing aggregation, followed by a single-transaction standard, do not expand the earlier provision. It further explains that section 40(a)(ia) disallows otherwise deductible expenditure and cannot apply where player payouts were neither debited to the Profit and Loss Account nor claimed as deductions. Payments for advertising-platform access to a non-resident are discussed as not constituting royalty or fees for technical services, following an earlier coordinate-Bench approach.
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