https://www.taxtmi.com/caselaws?id=275515 In a lottery business carried on on a principal-to-principal basis, amounts passed on to sub-agents were treated as the value of prize-winning tickets and not as commission or remuneration for services. On that footing, the TDS obligation under section 194G or section 194H did not arise because the relationship was not one of principal and agent. As the foundational tax-deduction requirement was absent, disallowance under section 40(a)(ia) could not be sustained on these facts. The payments were therefore held not liable to TDS as commission or remuneration. en-us Tue, 25 Oct 2016 00:00:00 +0530 Sat, 06 Oct 2018 09:56:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275515 In a lottery business carried on on a principal-to-principal basis, amounts passed on to sub-agents were treated as the value of prize-winning tickets and not as commission or remuneration for services. On that footing, the TDS obligation under section 194G or section 194H did not arise because the relationship was not one of principal and agent. As the foundational tax-deduction requirement was absent, disallowance under section 40(a)(ia) could not be sustained on these facts. The payments were therefore held not liable to TDS as commission or remuneration. Case-Laws Income Tax Tue, 25 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275515