2015 (6) TMI 1095

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....ER PER I.P. BANSAL, J.M: This is an appeal filed by the Revenue and it is directed against order passed by Ld. CIT(A)-14, Mumbai dated 15/10/2013 for assessment year 2010-11. Grounds of appeal read as under: "1. On the facts and circumstances of the case and in law, the learned CIT(A) erred in allowing the appeal of the assessee on the basis of reasoning that bank guarantee charges ....

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....ues bank guarantee on behalf of assessee, there is no principal agent relationship between bank and assessee and, therefore, assesee is not required to deduct tax at source under section 194H from payments of bank guarantee commission made to the bank. 3. Ld. DR did not controvert such submission of Ld. AR. 4. In this view of the situation we have heard both the parties. Ld. CIT(A) while dec....