Interest paid under s.201(1A) for delayed TDS remittance was...

Interest paid under s.201(1A) for delayed TDS remittance was held not compensatory and hence not deductible as business expenditure under s.37(1), following binding precedent; the disallowance was sustained. Payments to a foreign expert were held to exhibit employer-employee attributes; GST treatment was irrelevant, and the amounts were treated as salary requiring TDS under s.192, so disallowance under s.40(a)(i) for non-deduction was upheld. Disallowance of head-office staff reimbursements under s.44DA lacked a clear adjudication and was remitted to the AO for fresh decision with opportunity of hearing. Bank/performance guarantee charges were not "commission or brokerage" absent a principal-agent relationship, so disallowance under s.40(a) was deleted. Challenge to mere initiation of penalty under s.270A was held non-maintainable. - ITAT

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