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    <title>2023 (8) TMI 877 - ITAT MUMBAI</title>
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    <description>The Tribunal dismissed the grounds concerning ESOP provisions and discounts offered to dealers, affirming the CIT(A)&#039;s decisions. It ruled that tax on ESOP provisions is deductible at the time of share allotment, and discounts to dealers are rebates, not commissions, thus not subject to TDS. Regarding year-end provisions, the Tribunal partially allowed the appeal, directing the AO to calculate interest under section 201(1A) due to delayed TDS deduction, as the provisions were made on a reasonable basis and payees were identified. All six appeals were resolved in a similar manner, leading to a partial allowance of the appeals.</description>
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      <title>2023 (8) TMI 877 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=441898</link>
      <description>The Tribunal dismissed the grounds concerning ESOP provisions and discounts offered to dealers, affirming the CIT(A)&#039;s decisions. It ruled that tax on ESOP provisions is deductible at the time of share allotment, and discounts to dealers are rebates, not commissions, thus not subject to TDS. Regarding year-end provisions, the Tribunal partially allowed the appeal, directing the AO to calculate interest under section 201(1A) due to delayed TDS deduction, as the provisions were made on a reasonable basis and payees were identified. All six appeals were resolved in a similar manner, leading to a partial allowance of the appeals.</description>
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