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    <title>2025 (6) TMI 1947 - ITAT COCHIN</title>
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    <description>The HC dismissed the appeal, upholding the disallowance of guarantee commission paid by a state-owned company to the State Government of Kerala under section 40(a)(iib) of the Income-tax Act. The court relied on a binding SC precedent in Kerala State Beverages Corporation case that settled the issue against the appellant. The HC ruled that the PCIT&#039;s revisional order under section 263 directing disallowance was valid and had attained finality, precluding further challenge before the Appellate Tribunal. The payment was held to fall within section 40(a)(iib) requiring TDS deduction, and the revisional jurisdiction was properly exercised as the original assessment was erroneous and prejudicial to revenue.</description>
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    <pubDate>Wed, 14 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1947 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=773834</link>
      <description>The HC dismissed the appeal, upholding the disallowance of guarantee commission paid by a state-owned company to the State Government of Kerala under section 40(a)(iib) of the Income-tax Act. The court relied on a binding SC precedent in Kerala State Beverages Corporation case that settled the issue against the appellant. The HC ruled that the PCIT&#039;s revisional order under section 263 directing disallowance was valid and had attained finality, precluding further challenge before the Appellate Tribunal. The payment was held to fall within section 40(a)(iib) requiring TDS deduction, and the revisional jurisdiction was properly exercised as the original assessment was erroneous and prejudicial to revenue.</description>
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      <pubDate>Wed, 14 May 2025 00:00:00 +0530</pubDate>
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