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    <title>2024 (7) TMI 225 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC upheld the Tribunal&#039;s decision favoring the assessee on two issues. First, regarding TDS u/s 195 on payments to non-residents for sampling and consultancy services, the court held that the assessee could not be expected to deduct tax at source from payments that became taxable only due to retrospective amendments by Finance Act 2010, applying the principle that law does not demand the impossible. Second, concerning expenditure on temple repairs and school construction, the court ruled these were allowable revenue expenditures incurred for business exigencies to maintain cordial relations with villagers around mining areas, as no capital asset was acquired by the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=755005</link>
      <description>The Bombay HC upheld the Tribunal&#039;s decision favoring the assessee on two issues. First, regarding TDS u/s 195 on payments to non-residents for sampling and consultancy services, the court held that the assessee could not be expected to deduct tax at source from payments that became taxable only due to retrospective amendments by Finance Act 2010, applying the principle that law does not demand the impossible. Second, concerning expenditure on temple repairs and school construction, the court ruled these were allowable revenue expenditures incurred for business exigencies to maintain cordial relations with villagers around mining areas, as no capital asset was acquired by the assessee.</description>
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