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TDS u/s 194C - Disallowance u/s 40(a)(ia) - Non deduction of TDS on minimum guarantee expense - The Tribunal analyzed the business model of the assessee and concluded that no work was carried out, thus section 194C of the Act did not apply. The ITAT directed the Assessing Officer to delete the disallowed expenses.
TDS u/s 194C - Disallowance u/s 40(a)(ia) - Non deduction of TDS on minimum guarantee expense - The Tribunal analyzed the business model of the assessee and concluded that no work was carried out, thus section 194C of the Act did not apply. The ITAT directed the Assessing Officer to delete the disallowed expenses.
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