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of Appellant, a Kachha Adhatiya (Commission Agent), claimed credit for TDS deducted u/ss 194H and 194Q. The Tribunal held that, as per CBDT Circular No. 452, for Kachha Artias, only commission income is considered for Section 44AB, not turnover from sales on behalf of principals. The appellant made purchases from farmers on behalf of buyers and raised invoices for the same amount, receiving commission on which TDS was deducted u/s 194H. Buyers also deducted TDS u/s 194Q. Relying on case law, the Tribunal directed the AO to allow credit for TDS deducted u/ss 194H and 194Q.
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