Assessee followed joint venture model for sharing revenue with...

Assessee followed joint venture model for sharing revenue with collaborators as per franchise agreement. Assessee recorded all revenues, incurred expenditure, and shared surplus with collaborators after adjusting expenses. Tribunal held that sharing surplus is merely sharing revenue, not claiming expenditure, as collaborators did not render services to assessee. Provisions for tax deduction at source not applicable since collaborators did not provide services. Tribunal upheld assessee's claim of expenditure for sharing surplus, which was essentially sharing revenue as per agreement. Decision favored assessee against revenue authorities.

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