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    <title>2023 (2) TMI 190 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the payments made by the non-resident company to schools for referring students to purchase textbooks constituted &#039;commission or brokerage&#039; under Section 194H of the Income Tax Act. Consequently, 30% of the expenditure was disallowed under Section 40(a)(ia) for failure to deduct tax at source. The Tribunal directed the Assessing Officer to verify if the recipients had disclosed the receipts in their income tax returns, and if so, to delete the disallowance. The appeal was partly allowed for statistical purposes, subject to verification of recipient disclosures.</description>
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    <pubDate>Tue, 13 Dec 2022 00:00:00 +0530</pubDate>
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      <title>2023 (2) TMI 190 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=433675</link>
      <description>The Tribunal held that the payments made by the non-resident company to schools for referring students to purchase textbooks constituted &#039;commission or brokerage&#039; under Section 194H of the Income Tax Act. Consequently, 30% of the expenditure was disallowed under Section 40(a)(ia) for failure to deduct tax at source. The Tribunal directed the Assessing Officer to verify if the recipients had disclosed the receipts in their income tax returns, and if so, to delete the disallowance. The appeal was partly allowed for statistical purposes, subject to verification of recipient disclosures.</description>
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