https://www.taxtmi.com/caselaws?id=446814 The ITAT Delhi ruled in favor of the assessee on multiple TDS-related disallowances. Regarding fees paid to FOWC, the Tribunal held no disallowance was warranted under Section 40(a)(i) as the second proviso, though inserted w.e.f. 1.4.2020, was curative and declaratory in nature requiring retrospective application. For FOM fees, the CIT(A)'s deletion was upheld since the chargeable sum resulted in loss, requiring no TDS withholding. The bank guarantee commission disallowance under Section 194H was also rejected, following the Tribunal's earlier decision that no TDS was required on such payments. en-us Wed, 29 Nov 2023 00:00:00 +0530 Mon, 11 Dec 2023 15:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446814 The ITAT Delhi ruled in favor of the assessee on multiple TDS-related disallowances. Regarding fees paid to FOWC, the Tribunal held no disallowance was warranted under Section 40(a)(i) as the second proviso, though inserted w.e.f. 1.4.2020, was curative and declaratory in nature requiring retrospective application. For FOM fees, the CIT(A)'s deletion was upheld since the chargeable sum resulted in loss, requiring no TDS withholding. The bank guarantee commission disallowance under Section 194H was also rejected, following the Tribunal's earlier decision that no TDS was required on such payments. Case-Laws Income Tax Wed, 29 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446814