Retrospective application of CBDT Circular clarifying no TDS to be deducted for Bank Guarantee Commission

Onkareshwar Properties (P) Ltd. Vs ACIT (ITAT Delhi) Conclusion: No disallowance u/s 40(a)(ia) could be made for non deduction of TDS on bank commission / guarantee fee as CBDT vide Circular No. 56/2012 had clarified that no TDS was required to be deducted on bank guarantee commission, etc. and the same was retrospective applicable. Held: AO had made disallowance on the ground that assessee should have deducted TDS on bank commission / guarantee fee and held that CBDT Circular No. 56/2012 was only applicable from 1st January, 2013. It was noted that CBDT had clarified that no TDS was required...