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    <title>2025 (9) TMI 1500 - ITAT MUMBAI</title>
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    <description>Payments to persons who merely referred prospective insurance customers were not insurance commission under section 194D because the recipients were not appointed as insurance agents and had no principal-agent relationship with the insurer. The commission-like payments therefore did not attract tax deduction at source under that provision, and disallowance under section 40(a)(ia) was not sustainable on these facts. The article also notes that an ad hoc 30% disallowance of referral commission was unsupported where the expenditure was backed by confirmations, bills, vouchers, payment details, and responses to notices and summons, making the arbitrary disallowance unsustainable.</description>
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    <pubDate>Tue, 23 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 1500 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=779011</link>
      <description>Payments to persons who merely referred prospective insurance customers were not insurance commission under section 194D because the recipients were not appointed as insurance agents and had no principal-agent relationship with the insurer. The commission-like payments therefore did not attract tax deduction at source under that provision, and disallowance under section 40(a)(ia) was not sustainable on these facts. The article also notes that an ad hoc 30% disallowance of referral commission was unsupported where the expenditure was backed by confirmations, bills, vouchers, payment details, and responses to notices and summons, making the arbitrary disallowance unsustainable.</description>
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