CIT v. Larsen & Toubro Ltd. (2019) 260 Taxman 271/ 307 CTR 464/ 174 DTR 246 (Bom.)(HC)

S. 194H : Deduction at source–Commission or brokerage–Bank guarantee commission is not in the nature of commission paid to agent, it is bank charges for providing one of banking services – Not liable to deduct tax at source.

Dismissing the appeal of the revenue the Court held that, Bank guarantee  commission is not in the nature of commission paid to agent, it is bank charges for providing one of banking services. Accordingly not liable to deduct tax at source. (AY. 2010-11)