Appeal partly allowed: wildlife eco-adventure tours not tour operator; accommodations not renting; training taxable; penalties and extended limitation...
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ITAT allowed the appeal of the assessee and set aside the orders of the lower authorities, holding that provisions of section 194H read with sections 201 and 201(1A) were not attracted for AY 2015-16. The Tribunal found no principal-agent relationship between the assessee and the payment gateway operators (CC Avenues and Zaaki payment services), treated the transactions as outside the scope of commission liable to TDS, and relied on relevant judicial precedent and CBDT instruction. The Tribunal directed the AO to delete the impugned demand under sections 201 and 201(1A) and allowed all grounds of appeal raised by the assessee.
ITAT allowed the appeal of the assessee and set aside the orders of the lower authorities, holding that provisions of section 194H read with sections 201 and 201(1A) were not attracted for AY 2015-16. The Tribunal found no principal-agent relationship between the assessee and the payment gateway operators (CC Avenues and Zaaki payment services), treated the transactions as outside the scope of commission liable to TDS, and relied on relevant judicial precedent and CBDT instruction. The Tribunal directed the AO to delete the impugned demand under sections 201 and 201(1A) and allowed all grounds of appeal raised by the assessee.
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