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    <title>2022 (1) TMI 841 - KARNATAKA HIGH COURT</title>
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    <description>Retention of 2.5% of passenger service fee invoice value by airlines was treated as commission within the meaning of section 194H, so the proviso to section 40(a)(ia) required verification whether tax had been deducted and paid on the retained amount; the remand for that factual examination was held appropriate. The court also stated that a company cannot follow a hybrid accounting method by recognising expenditure on a mercantile basis while deferring related income to a later year on receipt basis, and the same-year matching principle must be maintained to avoid double taxation. The connected section 14A challenge was treated as academic.</description>
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