No disallowance of discount for Non-Deduction of TDS

Dish Tv India Limited  Vs. ACIT (ITAT Mumbai) The issue under consideration is whether disallowing expenditure in the nature of discount under section 40(a)(ia) for non-deduction of tax u/s 194J by considering it as commission is justified in law? ITAT states that, On the basis of the document and the issue involved we are of the view that examination of these documents as a whole along with the terms and conditions of the agreement entered into between the assessee and the distributor in respect of talk time card is essential to determine the true nature of the transaction whether the transa...