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    <title>2023 (1) TMI 62 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=432315</link>
    <description>The Tribunal ruled in favor of the assessee, holding that the ceding commission was a reimbursement of expenses and not subject to TDS under section 194D. The Tribunal relied on judicial precedents from the Madras High Court and Bombay High Court, which had ruled similarly in favor of the assessee. The Tribunal also noted that the DRP had erred in relying on the ITAT Chennai decision, which was not applicable to the facts of the case. Consequently, the appeal was allowed, and the disallowance under section 40(a)(ia) was overturned. The Stay Application was rendered infructuous due to the favorable ruling on the main appeal.</description>
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    <pubDate>Fri, 13 May 2022 00:00:00 +0530</pubDate>
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      <title>2023 (1) TMI 62 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=432315</link>
      <description>The Tribunal ruled in favor of the assessee, holding that the ceding commission was a reimbursement of expenses and not subject to TDS under section 194D. The Tribunal relied on judicial precedents from the Madras High Court and Bombay High Court, which had ruled similarly in favor of the assessee. The Tribunal also noted that the DRP had erred in relying on the ITAT Chennai decision, which was not applicable to the facts of the case. Consequently, the appeal was allowed, and the disallowance under section 40(a)(ia) was overturned. The Stay Application was rendered infructuous due to the favorable ruling on the main appeal.</description>
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