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    <title>2024 (5) TMI 1176 - ITAT MUMBAI</title>
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    <description>ITAT MUMBAI - AT held that the part-interest retained by originating NBFCs on directly assigned loans constituted consideration for the purchase, not &quot;interest&quot; payable by the assignee, and therefore no TDS was deductible under s.194A. The payments were also not commission/brokerage under s.194H because NBFCs did not act as agent, nor were they professional/technical fees under s.194J. Consequently tax under s.201(1) and interest under s.201(1A) were not leviable on the assignee; the tribunal decided in favour of the assignee.</description>
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    <pubDate>Tue, 07 May 2024 00:00:00 +0530</pubDate>
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      <title>2024 (5) TMI 1176 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=753123</link>
      <description>ITAT MUMBAI - AT held that the part-interest retained by originating NBFCs on directly assigned loans constituted consideration for the purchase, not &quot;interest&quot; payable by the assignee, and therefore no TDS was deductible under s.194A. The payments were also not commission/brokerage under s.194H because NBFCs did not act as agent, nor were they professional/technical fees under s.194J. Consequently tax under s.201(1) and interest under s.201(1A) were not leviable on the assignee; the tribunal decided in favour of the assignee.</description>
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