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    <title>2025 (9) TMI 1500 - ITAT MUMBAI</title>
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    <description>ITAT allowed the appeal. The tribunal held the AO&#039;s 30% adhoc disallowance of referral commissions paid to 14 individuals was unsustainable because payments were admitted, supporting vouchers and confirmations were on record, and no rationale for the 30% rate was shown. Further, the payments were held to be sales-promotion/referral commissions and not insurance-agent commissions within s.194D; at most they could fall under s.194H or s.194C, but no tax deduction obligation arose as receipts were below threshold and the payer was an individual. Accordingly disallowance under s.40(a)(ia) was overturned.</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>ITAT allowed the appeal. The tribunal held the AO&#039;s 30% adhoc disallowance of referral commissions paid to 14 individuals was unsustainable because payments were admitted, supporting vouchers and confirmations were on record, and no rationale for the 30% rate was shown. Further, the payments were held to be sales-promotion/referral commissions and not insurance-agent commissions within s.194D; at most they could fall under s.194H or s.194C, but no tax deduction obligation arose as receipts were below threshold and the payer was an individual. Accordingly disallowance under s.40(a)(ia) was overturned.</description>
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      <pubDate>Tue, 23 Sep 2025 00:00:00 +0530</pubDate>
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