In the result, all the appeals under consideration are allowed
Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahman
194H would come into play only when the particular expenses fell under the head "commission" and its nexus with the business of the assessee was proved beyond doubt. He rejected the logic of the assessee as irrelevant, i.e. the payments were through cheques and the TDS was made and therefore, the expenditure should be treated as genuine. According