https://www.taxtmi.com/caselaws?id=760261 The ITAT Delhi ruled in favor of the assessee regarding expenditure claims for surplus sharing with collaborators. The court distinguished between franchise and joint venture models, noting the assessee followed a JV model where it recorded all revenue and shared surplus after adjusting expenditures. The tribunal held that surplus sharing constituted revenue sharing rather than expenditure claims, as collaborators rendered no services to the assessee. Consequently, TDS provisions were deemed inapplicable. The AO had incorrectly mixed up the methods adopted by the assessee. The appeal was decided against the revenue department. en-us Wed, 09 Oct 2024 00:00:00 +0530 Fri, 18 Oct 2024 09:14:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760261 The ITAT Delhi ruled in favor of the assessee regarding expenditure claims for surplus sharing with collaborators. The court distinguished between franchise and joint venture models, noting the assessee followed a JV model where it recorded all revenue and shared surplus after adjusting expenditures. The tribunal held that surplus sharing constituted revenue sharing rather than expenditure claims, as collaborators rendered no services to the assessee. Consequently, TDS provisions were deemed inapplicable. The AO had incorrectly mixed up the methods adopted by the assessee. The appeal was decided against the revenue department. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760261