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    <title>2022 (12) TMI 1590 - ITAT MUMBAI</title>
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    <description>Discount allowed to distributors as a reduction from MRP at the time of sale of medicines constituted a trade discount and not &quot;commission or brokerage&quot; within s. 194H; since the relationship was of principal-to-principal and no income by way of commission arose, no TDS was deductible, and the relief granted to the assessee was upheld. Interest paid to micro and small enterprises for delayed payment of purchase price had a direct nexus with trade liability and did not qualify as &quot;interest&quot; under s. 2(28A) for purposes of s. 194A; consequently, the assessee could not be treated as an assessee-in-default under s. 201, and the assessee&#039;s position was sustained.</description>
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      <title>2022 (12) TMI 1590 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465543</link>
      <description>Discount allowed to distributors as a reduction from MRP at the time of sale of medicines constituted a trade discount and not &quot;commission or brokerage&quot; within s. 194H; since the relationship was of principal-to-principal and no income by way of commission arose, no TDS was deductible, and the relief granted to the assessee was upheld. Interest paid to micro and small enterprises for delayed payment of purchase price had a direct nexus with trade liability and did not qualify as &quot;interest&quot; under s. 2(28A) for purposes of s. 194A; consequently, the assessee could not be treated as an assessee-in-default under s. 201, and the assessee&#039;s position was sustained.</description>
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      <pubDate>Tue, 20 Dec 2022 00:00:00 +0530</pubDate>
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