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    <title>2025 (5) TMI 2223 - ITAT MUMBAI</title>
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    <description>The dominant issue was whether discounts allowed to stockists and interest paid for delayed payments to MSMEs attracted TDS under ss. 194H and 194A, warranting disallowance/addition for non-deduction. The Tribunal held that both issues were squarely covered by coordinate bench decisions in the anonymized assessee&#039;s own case for earlier assessment years on identical facts, and applied the rule of consistency to adopt the same legal position. Consequently, the additions made by the AO were deleted and the Revenue&#039;s grounds were dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=465491</link>
      <description>The dominant issue was whether discounts allowed to stockists and interest paid for delayed payments to MSMEs attracted TDS under ss. 194H and 194A, warranting disallowance/addition for non-deduction. The Tribunal held that both issues were squarely covered by coordinate bench decisions in the anonymized assessee&#039;s own case for earlier assessment years on identical facts, and applied the rule of consistency to adopt the same legal position. Consequently, the additions made by the AO were deleted and the Revenue&#039;s grounds were dismissed.</description>
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