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, considered a case involving the revision u/s 263 for non-deduction of tax at source on salary and commission payments. The CIT argued that the AO did not disallow u/s 40(a)(ia). The ITAT held that if the recipient of income has declared and paid taxes on income where no TDS was deducted, the assessee is not in default per Second Proviso to Section 40(a)(ia). The ITAT found that the recipient had declared and paid taxes on salary and commission income. The ITAT disagreed with the PCIT's failure to consider these facts during the 263 proceedings. The ITAT allowed the appeal, stating that TDS on commission should be disallowed and added to the assessee's income for the relevant assessment year.
The ITAT, an Appellate Tribunal, considered a case involving the revision u/s 263 for non-deduction of tax at source on salary and commission payments. The CIT argued that the AO did not disallow u/s 40(a)(ia). The ITAT held that if the recipient of income has declared and paid taxes on income where no TDS was deducted, the assessee is not in default per Second Proviso to Section 40(a)(ia). The ITAT found that the recipient had declared and paid taxes on salary and commission income. The ITAT disagreed with the PCIT's failure to consider these facts during the 263 proceedings. The ITAT allowed the appeal, stating that TDS on commission should be disallowed and added to the assessee's income for the relevant assessment year.
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