Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
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