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Jurisdiction of the National Faceless Assessment Centre (NFAC) to change the "head" of Tax Deducted at Source (TDS) provision from "salary u/s 192" to "commission u/s 194A" in proceedings u/s 154 read with Section 200A. The assessee's contention is that Section 200A, being a complete code for processing TDS returns, overrides other general provisions, and the NFAC cannot change the head of TDS applicability once TDS has been deducted u/s 192 at the time of payment. The Tribunal accepted the assessee's arguments, concluding that the NFAC erred in law and on facts in raising the demand by changing the head from "salary" to "commission," and the demand was reversed.
Jurisdiction of the National Faceless Assessment Centre (NFAC) to change the "head" of Tax Deducted at Source (TDS) provision from "salary u/s 192" to "commission u/s 194A" in proceedings u/s 154 read with Section 200A. The assessee's contention is that Section 200A, being a complete code for processing TDS returns, overrides other general provisions, and the NFAC cannot change the head of TDS applicability once TDS has been deducted u/s 192 at the time of payment. The Tribunal accepted the assessee's arguments, concluding that the NFAC erred in law and on facts in raising the demand by changing the head from "salary" to "commission," and the demand was reversed.
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