TDS under Section 194C treated fixed-percentage commissions as contractual payments, leading to disallowance under Section 40(a)(ia).

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....The note addresses TDS obligations where payments calculated as fixed percentages of net sales were treated as reimbursements; it states that such payments lacked bills or vouchers and were contractual consideration for services (advertising, sales promotion, handling, storage). The legal principle applied is that genuine reimbursements must correspond to verifiable post-facto expenses supported by documentation, whereas fixed-percentage payments that are contractual fall within the TDS charging provisions and require deduction at payment or credit. Consequently, failure to deduct justified disallowance under the relevant tax disallowance provision.....