No TDS on Stockist Discounts, ESOP Grants & MSME Interest: ITAT Mumbai

DCIT (TDS) Vs Novartis Healthcare Private Limited (ITAT Mumbai) Stockist Discounts Held Not Commission, No TDS Under Section 194H; ESOP TDS Liability Arises Only on Exercise, Not on Grant; Delayed MSME Payment Interest Not Subject to TDS Under Section 194A; Pharma Distribution Model Treated as Principal-to-Principal; No Assessee-in-Default Status Without Actual Commission or Interest Payment The appeal arose from a TDS survey conducted under section 133A(2A) to verify tax deduction compliance by a pharmaceutical company engaged in manufacturing and trading of drugs. Based on the survey, the As...