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    <title>2020 (12) TMI 1358 - ITAT MUMBAI</title>
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    <description>Automated stock exchange trading facilities available uniformly to members were not technical services, so lease line, V-SAT and transaction charges did not attract TDS under section 194J and the related disallowance under section 40(a)(ia) was deleted. Security Transaction Tax collected from clients and shown only as a liability was not the assessee&#039;s expenditure, so disallowance under section 43B(a) did not arise. The transfer pricing adjustments on brokerage commission and brand fee/royalty were deleted by applying the assessee&#039;s earlier-year rulings, with TNMM treated as the appropriate method for brokerage and CUP rejected on the material for royalty. TDS credit and dividend distribution tax issues were remitted for verification and consequential relief.</description>
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