TDS not deductible on bank guarantee commission

National Fertilizers Ltd Vs DCIT (ITAT Delhi)

Bank guarantee commission cannot be said to be a “commission” as intended to u/s 194H of the but it is in the nature of Bank charges charged by the bank for provision of services to the assessee. TDS not deductible.

Facts-

Assessee has preferred appeal on account of disallowance of bank guarantee commission invoking Section 40(a)(ia).

Revenue has preferred appeal on account of deletion of addition of notional accrued interest without considering the fact that the assessee was following mercantile system of accounting.

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