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    <title>2022 (9) TMI 1519 - ITAT DELHI</title>
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    <description>ITAT Delhi held that discount allowed to advertising agencies under a principal-to-principal arrangement was trade discount, not commission, so section 194H was not attracted and disallowance under section 40(a)(ia) could not stand. It also held that disallowance under section 14A read with Rule 8D must be confined to investments that actually yielded exempt income during the relevant year, and the restricted computation was upheld. The revenue&#039;s challenge failed on both issues, and relief to the assessee was affirmed.</description>
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      <title>2022 (9) TMI 1519 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=310301</link>
      <description>ITAT Delhi held that discount allowed to advertising agencies under a principal-to-principal arrangement was trade discount, not commission, so section 194H was not attracted and disallowance under section 40(a)(ia) could not stand. It also held that disallowance under section 14A read with Rule 8D must be confined to investments that actually yielded exempt income during the relevant year, and the restricted computation was upheld. The revenue&#039;s challenge failed on both issues, and relief to the assessee was affirmed.</description>
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      <pubDate>Fri, 30 Sep 2022 00:00:00 +0530</pubDate>
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