Bank Guarantee Commission not liable to TDS U/s. 194H as it is is not a transaction between principal and agent

Kotak Securities Limited Vs. DCIT (ITAT Mumbai)- When we look at the connotations of expression ‘commission or brokerage’ in its cognate sense, as in the light of the principle of noscitur a sociis as we are obliged to, in our considered view, scope of expression ‘commission’, for this purpose, will be confined to ‘an allowance, recompense or reward made to agents, factors and brokers and others for effecting sales and carrying out business transactions’ and shall not extend to the payments, such as ‘bank guarantee commiss

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