https://www.taxtmi.com/caselaws?id=769438 ITAT Mumbai dismissed revenue's appeal regarding TDS applicability under sections 194H and 194I on commission payments to franchisees/LFS. The tribunal held that agreements between assessee and franchisees/LFS established principal-to-principal relationship, not agency. Transactions were sales on principal-to-principal basis, not commission payments requiring TDS under section 194H. Discounts offered to LFS could not be treated as rent under section 194I since assessee had no possession or control over demarcated space within LFS premises. LFS retained full operational control while assessee employees only assisted customers occasionally. Revenue failed to establish commission payments or space occupation warranting TDS deduction. en-us Fri, 11 Apr 2025 00:00:00 +0530 Wed, 23 Apr 2025 17:08:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769438 ITAT Mumbai dismissed revenue's appeal regarding TDS applicability under sections 194H and 194I on commission payments to franchisees/LFS. The tribunal held that agreements between assessee and franchisees/LFS established principal-to-principal relationship, not agency. Transactions were sales on principal-to-principal basis, not commission payments requiring TDS under section 194H. Discounts offered to LFS could not be treated as rent under section 194I since assessee had no possession or control over demarcated space within LFS premises. LFS retained full operational control while assessee employees only assisted customers occasionally. Revenue failed to establish commission payments or space occupation warranting TDS deduction. Case-Laws Income Tax Fri, 11 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769438