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One-time gold purchase premium not subject to TDS u/s 194H; cannot be rectified u/s 154.

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....TDS u/s 194H - commission - payment of one time non-refundable premium to bank for purchase of gold - this transaction of payment of one time premium would effectively go to add to the purchase cost of the gold and cannot be categorised as commission - No TDS liability - Further, a debatable issue cannot be the subject matter of rectification proceedings u/s.154....

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