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of TDS u/s 194H - Higher rate of TDS @20% in absence of PAN - Commission paid to Primary Agriculture Cooperative Society (PACS) - The Tribunal examined the nature of transactions between the appellant and PACS. It found that the State Government, through its nodal agencies, controlled and directed the activities of PACS in procuring food grains, indicating an agency relationship. Consequently, the commission paid by the appellant to PACS was deemed liable for TDS under Section 194H. It also observed errors in the calculation of TDS, considering that PACS likely had PAN details and that the commission rate was not accurately applied.
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