Disallowance of Commission Expenses Due to Non-Deduction of TDS u/s 195; Arm's Length Deemed Irrelevant.

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Full Text of the Document

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....Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT....