CIT v. Royal Sundaram Alliance Insurance Co. Ltd. (2020)423 ITR 122 (Mad)(HC)

S. 194H : Deduction at source –Commission on reinsurance premium – Not liable to deduct tax at source .

Dismissing the appeal of the revenue the Court held that as a matter of industrial practice the payment was termed “commission on reinsurance premium received” but in substance it was discount on reinsurance premium received by an insurance company from another  insurance company, accordingly not liable to deduct tax at source .