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    <title>2019 (9) TMI 200 - BOMBAY HIGH COURT</title>
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    <description>The Tribunal upheld the deletion of addition under section 40(a)(ia) rw section 194H of the Income Tax Act, 1961, amounting to Rs. 5,84,55,165. It found that the discounts given by the Respondent to a company were part of the sale transaction and not subject to tax deduction as commission. The Tribunal determined that the sale was on a principal-to-principal basis, not through an agent, based on the agreement terms. The decision emphasized the need to analyze transaction nature and agreements to ascertain tax implications accurately. The appeal was dismissed as it did not raise any substantial question of law.</description>
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      <title>2019 (9) TMI 200 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=385432</link>
      <description>The Tribunal upheld the deletion of addition under section 40(a)(ia) rw section 194H of the Income Tax Act, 1961, amounting to Rs. 5,84,55,165. It found that the discounts given by the Respondent to a company were part of the sale transaction and not subject to tax deduction as commission. The Tribunal determined that the sale was on a principal-to-principal basis, not through an agent, based on the agreement terms. The decision emphasized the need to analyze transaction nature and agreements to ascertain tax implications accurately. The appeal was dismissed as it did not raise any substantial question of law.</description>
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