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

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