TDS on Pigmy Deposits: Payments Not Classified as Commission, Section 194H Non-Applicable for Disallowance.

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....TDS u/s 194H OR 192 - Addition u/s 40(i)(a) - TDS was not deducted on pigmy deposits commission - the authorities below could not have treated the payment made by assessee to the pigmy deposit collectors as commission for making disallowance under section 40(a)(ia) of the Act for non-deduction of TDS under section 194H- AT....