2024 (7) TMI 587

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....Respondent : Shri Arun Dwivedi, Counsel ORDER PER: SUSHRUT ARVIND DHARMADHIKARI, J. Heard on the question of admission. 2. The issue raised in this appeal under Section 260-A of the Income Tax Act, 1961 (hereafter referred to as 'Act, 1961') relates to liability to deduct the tax at source under Section 194H of the Act, 1961 on the amount which, as per Revenue, commission payable to an....

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....e has been answered by the Apex Court vide its judgment dated 28.02.2024 in Civil Appeal No. 7257/2011 and came to the following conclusion : ''42. In view of the aforesaid discussion, we hold that the assessees would not be under a legal obligation to deduct tax at source on the income/profit component in the payments received by the distributors/franchisees from the third parties/custo....