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    <title>2024 (8) TMI 868 - ITAT DELHI</title>
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    <description>The ITAT Delhi allowed the assessee&#039;s appeal regarding membership fee taxation, accepting the methodology of recognizing revenue on a deferred basis for beauty health packages where members pay advances for services. The tribunal confirmed that no disallowance under Section 14A was warranted as no exempt income was earned. Interest paid to NOIDA on plot installments was correctly treated as capital expenditure and added to land cost rather than allowed as business expenditure per Section 36(1)(iii) proviso. The tribunal rejected ad-hoc disallowances on business promotion and related expenses without proper rationale. Regarding TDS under Section 194H, the tribunal held that credit card transaction charges to banks are not subject to TDS based on CBDT Notification 56/2012 and Delhi HC precedent.</description>
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      <link>https://www.taxtmi.com/caselaws?id=757164</link>
      <description>The ITAT Delhi allowed the assessee&#039;s appeal regarding membership fee taxation, accepting the methodology of recognizing revenue on a deferred basis for beauty health packages where members pay advances for services. The tribunal confirmed that no disallowance under Section 14A was warranted as no exempt income was earned. Interest paid to NOIDA on plot installments was correctly treated as capital expenditure and added to land cost rather than allowed as business expenditure per Section 36(1)(iii) proviso. The tribunal rejected ad-hoc disallowances on business promotion and related expenses without proper rationale. Regarding TDS under Section 194H, the tribunal held that credit card transaction charges to banks are not subject to TDS based on CBDT Notification 56/2012 and Delhi HC precedent.</description>
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