https://www.taxtmi.com/caselaws?id=784596 Interest paid under s.201(1A) for delayed remittance of TDS was held not deductible under s.37(1) because binding HC precedent treats such interest as not compensatory and hence not allowable; the disallowance was sustained. Payments to an overseas expert were found to bear attributes of an employer-employee relationship; GST treatment was held irrelevant for characterising income under the Act, so the amount was treated as salary requiring TDS under s.192, and for non-deduction the disallowance under s.40(a)(i) was upheld. Disallowance of head-office staff expense reimbursements under s.44DA lacked DRP adjudication, so it was set aside to the AO for fresh decision. Bank/performance guarantee charges were held not "commission" absent a principal-agent relationship, so s.194H did not apply and the s.40(a) disallowance was deleted. Challenge to initiation of penalty under s.270A was held not maintainable. en-us Fri, 21 Nov 2025 00:00:00 +0530 Thu, 08 Jan 2026 08:22:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784596 Interest paid under s.201(1A) for delayed remittance of TDS was held not deductible under s.37(1) because binding HC precedent treats such interest as not compensatory and hence not allowable; the disallowance was sustained. Payments to an overseas expert were found to bear attributes of an employer-employee relationship; GST treatment was held irrelevant for characterising income under the Act, so the amount was treated as salary requiring TDS under s.192, and for non-deduction the disallowance under s.40(a)(i) was upheld. Disallowance of head-office staff expense reimbursements under s.44DA lacked DRP adjudication, so it was set aside to the AO for fresh decision. Bank/performance guarantee charges were held not "commission" absent a principal-agent relationship, so s.194H did not apply and the s.40(a) disallowance was deleted. Challenge to initiation of penalty under s.270A was held not maintainable. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784596