https://www.taxtmi.com/caselaws?id=773642 The ITAT Mumbai allowed the assessee's appeal regarding disallowance under section 40(a)(ia) for target, consistency, and cash discounts provided to spare parts dealers. The tribunal held that discounts given to dealers were genuine sales discounts under principal-to-principal agreements, not commission payments requiring TDS deduction. Following the SC precedent in Ahmadabad Stamp Vendors Association, the tribunal found no agency relationship existed between the assessee and dealers. The AO and CIT(A) failed to investigate the nature of dealer agreements or provide adverse findings on contractual terms, making the disallowance unjustified. en-us Fri, 13 Jun 2025 00:00:00 +0530 Thu, 26 Jun 2025 08:35:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773642 The ITAT Mumbai allowed the assessee's appeal regarding disallowance under section 40(a)(ia) for target, consistency, and cash discounts provided to spare parts dealers. The tribunal held that discounts given to dealers were genuine sales discounts under principal-to-principal agreements, not commission payments requiring TDS deduction. Following the SC precedent in Ahmadabad Stamp Vendors Association, the tribunal found no agency relationship existed between the assessee and dealers. The AO and CIT(A) failed to investigate the nature of dealer agreements or provide adverse findings on contractual terms, making the disallowance unjustified. Case-Laws Income Tax Fri, 13 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773642