https://www.taxtmi.com/caselaws?id=253415 The HC held that Section 194H was not attracted as HDFC was not an agent of the assessee but an independent party acting on a principal-to-principal basis. The payment received by the assessee from HDFC was net of a fee deducted by the acquiring bank, which facilitated the transaction without acting on behalf of the assessee. The bank assumed the risk and advanced payment before recovery from the credit card issuer. Consequently, the AO erred in invoking Section 40(a)(ia) and initiating penalty proceedings for concealment. The Tribunal's decision to quash the penalty and reject the revenue's claim was upheld. en-us Tue, 18 Nov 2014 00:00:00 +0530 Mon, 28 Jul 2025 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253415 The HC held that Section 194H was not attracted as HDFC was not an agent of the assessee but an independent party acting on a principal-to-principal basis. The payment received by the assessee from HDFC was net of a fee deducted by the acquiring bank, which facilitated the transaction without acting on behalf of the assessee. The bank assumed the risk and advanced payment before recovery from the credit card issuer. Consequently, the AO erred in invoking Section 40(a)(ia) and initiating penalty proceedings for concealment. The Tribunal's decision to quash the penalty and reject the revenue's claim was upheld. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253415