https://www.taxtmi.com/caselaws?id=782646 ITAT Delhi allowed the assessee's appeal, holding that minimum guarantee charges/guarantee fee paid to hotel/guest house owners were not "rent" under s.194I. Relying on SC precedent, the Tribunal found no lessor-lessee relationship and no exclusive right of use of rooms in favour of the assessee; rooms remained available to the general public via the assessee's e-platform. The guarantee fee was characterized as compensation for failure to meet agreed booking/price thresholds (unsold rooms and losses on sold rooms), not consideration for use of premises. Consequently, the assessee was not liable to deduct TDS under s.194C or s.194I, and disallowance under s.40(a)(ia) was deleted. en-us Fri, 21 Nov 2025 00:00:00 +0530 Sat, 29 Nov 2025 12:10:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782646 ITAT Delhi allowed the assessee's appeal, holding that minimum guarantee charges/guarantee fee paid to hotel/guest house owners were not "rent" under s.194I. Relying on SC precedent, the Tribunal found no lessor-lessee relationship and no exclusive right of use of rooms in favour of the assessee; rooms remained available to the general public via the assessee's e-platform. The guarantee fee was characterized as compensation for failure to meet agreed booking/price thresholds (unsold rooms and losses on sold rooms), not consideration for use of premises. Consequently, the assessee was not liable to deduct TDS under s.194C or s.194I, and disallowance under s.40(a)(ia) was deleted. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782646