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Assessee's Payments to Cooperatives Deemed Purchase Price, Not Commission; No Disallowance u/s 40(a)(ia) Needed.

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....Disallowance of Expenses u/s. 40(a)(ia) - Non deduction of TDS on commission - Pricing mechanism fixed by the Government of India, it is clear that the assessee has merely paid the purchase price as agreed. However, only to monitor the pricing, the cost components are separately shown so as to reimburse the assessee for any loss incurred by it in execution of PSS/MIS - Since the amount paid by the assessee to the Dist/State Level Cooperatives is only the purchase price and not in the nature of commission, no disallowance under section 40(a)(ia)is called for. - AT....

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Assessee's Payments to Cooperatives Deemed Purchase Price, Not Commission; No Disallowance u/s 40(a)(ia) Needed.