Existence of a Principal – Agent relationship must for applicability of Section 194H

SRL Ranbaxy Ltd vs. ACIT (ITAT Delhi) – In the present case, no income was found credited to the account of the collection centers. The loss on account of any damage was to be borne by the collection centers. The expenditure on salary/staff of the collection centers was to be borne by the collection centers on their own and the collection centers were free to charge any amount from the customers/patients. In view of the above discussion, we hold that (i) there is no Principal-Agent relationship between the assessee and the Collection

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