Assessee Wins Appeal: TDS on Distributor Discounts, Year-End Provisions, and Club Membership Fees Under Section 194H

ITAT allowed assessee's appeal on three key issues. First, TDS under s.194H not applicable on discounts given to prepaid distributors, following SC ruling in Bharti Cellular Ltd. Second, year-end accrual disallowances under s.40(a)(ia) reversed as provisions were credited back next day with actual bills and TDS deducted where applicable, following Karnataka HC decision in Subex Ltd. Third, club membership fees and subscription charges qualify as revenue expenditure not capital expenditure, following Karnataka HC precedent in Ingersoll-Rand India Ltd. Tribunal deleted all disallowances made by AO and ruled in favor of assessee on all grounds. .....

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