Tuesday, November 25, 2014

Section 194 H : TDS on Commission or Bokerage

Commission or brokerage.
194H. Any person, not being an individual or a Hindu undivided family, who is responsible for paying, on or after the 1st day of June, 2001, to a resident, any income by way of commission (not being insurance commission referred to in section 194D) or brokerage, shall, at the time of credit of such income to the account of the payee or at the time of payment of such income in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rate of [ten] per cent :
Provided that no deduction shall be made under this section in a case where the amount of such income or, as the case may be, the aggregate of the amounts of such income credited or paid or likely to be credited or paid during the financial year to the account of, or to, the payee, does not exceed [five thousand rupees] :
[Provided further that an individual or a Hindu undivided family, whose total sales, gross receipts or turnover from the business or profession carried on by him exceed the monetary limits specified under clause (a) or clause (b) of section 44AB during the financial year immediately preceding the financial year in which such commission or brokerage is credited or paid, shall be liable to deduct income-tax under this section:]
[Provided also that no deduction shall be made under this section on any commission or brokerage payable by Bharat Sanchar Nigam Limited or Mahanagar Telephone Nigam Limited to their public call office franchisees.]
Explanation.—For the purposes of this section,—
 (i)  "commission or brokerage" includes any payment received or receivable, directly or indirectly, by a person acting on behalf of another person for services rendered (not being professional services) or for any services in the course of buying or selling of goods or in relation to any transaction relating to any asset, valuable article or thing, not being securities;
(ii)  the expression "professional services" means services rendered by a person in the course of carrying on a legal, medical, engineering or architectural profession or the profession of accountancy or technical consultancy or interior decoration or such other profession as is notified by the Board for the purposes of section 44AA;
(iii)  the expression "securities" shall have the meaning assigned to it in clause (h) of section 2 of the Securities Contracts (Regulation) Act, 1956 (42 of 1956);
(iv)  where any income is credited to any account, whether called "Suspense account" or by any other name, in the books of account of the person liable to pay such income, such crediting shall be deemed to be credit of such income to the account of the payee and the provisions of this section shall apply accordingly.]

Q What is the meaning if Commission and how it is different from Discount ?

Answer; In Black's Law Dictionary, "Commission" and "Discount" are defined and explained as under:
"Commission:
The recompense, compensation or reward of an agent, salesman, executor, trustee, receiver, factor, broker, or bailee, when the same is calculated as a percentage on the amount of his transactions or on the profit to the principal. Weiner v. Swales 217 Md. 123. A fee paid to an agent or employee for transacting a piece of business or performing a service. Prayer v. Currin App. 280 SC 241. Compensation to an administrator or other fiduciary for the faithful discharge of his duties.
Discount:
In a general sense, an allowance or deduction made from a gross sum on any account whatever. In a more limited and technical sense, the taking of interest in advance.
A deduction from an original price or debt, allowed for paying promptly or in cash. Method of selling securities (e.g., treasury bills) which are issued below face value and redeemed at face value ...
To purchase an instrument or other right to the payment of money, usually for an amount less than the face amount or value of the right."

 Harihar Cotton Pressing Factory v. CIT [1960] 39 ITR 594 (Bom.) - The Bombay High Court explained the distinction between Commission and Discount  as under:
"The expression 'commission' has no technical meaning but both in legal and commercial acceptation of the term it has definite signification and is understood as an allowance for service or labour in discharging certain duties such as of an agent, factor, broker or any other person who manages the affairs or undertakes to do some work or renders some service to another. Mostly it is a percentage on price or value or upon the amount of money involved in any transaction of sale or service or the quantum of work involved in a transaction. It can be for a variety of services and is of the nature of recompense or reward for such services. 'Rebate', on the other hand, is a remission or a payment back and of the nature of a deduction from the gross amount. It is sometimes spoken of as a discount or a draw-back. The dictionary meaning of the term includes a refund to the purchaser of a thing or commodity of a portion of the price paid by him. It is not confined to a transaction of sale and includes any deduction or discount from a stipulated payment, charge or rate. It need not necessarily be taken out in advance of payment but may be handed back to the payer after he has paid the stipulated sum. The repayment need not be immediate. It can be made later and in case of persons who have continuous dealings with one another it is nothing unusual to do so.
Coromandel Fertilisers Ltd. v. UOT - In Coromandel Fertilisers Ltd. v. Union of India 1984 (17) ELT 607 (SC) (para. 12) and in Moped India Ltd. v. Asstt. Collector of Central Excise 1986 (23) ELT 8 (SC) (para. 6), the Apex Court applied the aforesaid principles while considering the question of arriving at the excisable value of mopeds. The trade discounts given to the dealers by the manufacturer were held to be liable to be deducted from the price charged to the dealers for the purpose of arriving at the excisable value of the goods, but the commissions given to the agents were held to be not deductible from the price for the purpose of arriving at the excisable value of the goods.
Q : Whether the sale of stamp paper to licensed vendor at discount of one per cent would  amount to commission and, therefore, Chief Treasury Officer was required to deduct tax at source under section 194-H ?
         Answer No, Section 194H of the Income-tax Act, 1961 - Deduction of tax at source -                 Commission or brokerage etc. - Whether discount given to stamp vendors for      
        purchasing stamps in bulk quantity was in nature of cash discount in transaction of sale,         and, therefore, section194H has no application to that transaction - Held, yes [2012] 25            taxmann.com 201 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v.            Ahmedabad Stamp Vendors Association

Section 194H of the Income-tax Act, 1961, read withRule 161 of U.P. Stamp Rules, 1942 - Deduction of tax at source - Commission or brokerage, etc. [Discount to Stamp Vendors] - Whether sale of stamp paper by Treasury Office to licensed vendor is a sale on principal to principal basis and there does not exist a relationship of agency in between them - Held, yes - Whether, therefore, sale of stamp paper to licensed vendor at discount of one per cent would not amount to commission and, therefore, Chief Treasury Officer was not required to deduct tax at source under section 194-H - Held, yes
[2013] 37 taxmann.com 391 (Allahabad) HIGH COURT OF ALLAHABAD
Chief Treasury Officer v.Union of India
Section 194H of the Income-tax Act, 1961 - Deduction of tax at source - Commission or brokerage, etc. - Petitioner was registered association of stamp vendors - Income-tax Department called upon State Government to deduct tax at source under section 194H from commission or brokerage paid to persons carrying on business as stamp vendors - Whether element of agency is to be there in case of all services or transactions contemplated by Explanation (i) to section 194H - Held, yes - Whether service in course of buying or selling of goods has to be something more than act of buying or selling of goods - Held, yes - Whether, where licensed stamp vendors take delivery of stamp papers on payment of full price less discount and they sell such stamp papers to retail customers, neither of two activities (buying from Government and selling to customers) can be termed as service in course of buying or selling of goods - Held, yes - Whether, therefore, discount made available to licensed stamp vendors under provisions of the Gujarat Stamp Supply and Sales Rules, 1987 is outside expression ‘commission or brokerage’ under section 194H and as such, no deduction of tax at source is required to be made from discount - Held, yes
[2002] 124 TAXMAN 628 (GUJ.) HIGH COURT OF GUJARAT Ahmedabad Stamp Vendors  Association v. Union of India
           
Q Commission paid by Mother Dairy to concessionaires who sell milk of assessee from booths owned by assessee  are liable for TDS u/s 194H ?
Answer No, Section 194H of the Income-tax Act 1961 - Deduction of tax at source - Commission or brokerage - Assessment Years 2004-05 and 2005-06 - Whether relationship between assessee-company (Dairy) and concessionaire, who sold milk and other products of assessee from booths owned by assessee, was principal-to-principal relationship inasmuch as milk and other products became property of concessionaire moment they took delivery of them and they were selling milk and other products in their own right as owners - Held, yes - Whether fact that concessionaires, were selling milk and other products from booths owned by assessee and were using assessee's equipment and furniture in course of sale of milk was not determinative of relationship between assessee and concessionaire with regard to sale of milk and other products - Held, yes - Whether, therefore, difference between MRP and price which concessionaire paid to assessee was his income from business and it could not be categorized as commission within meaning of section 194H - Held, yes [2012] 18 taxmann.com 49 (Delhi) HIGH COURT OF DELHI Commissioner of Income-tax v. Mother Dairy India Ltd.
Q Whether the Export Commission paid to foreing agent  for procuring order and pursuing payment from foreign buyer, is liable for tax Deduction?
Answer No, Section 9, read with sections 195 and 40(a)(i), of the Income-tax Act, 1961 - Income - Deemed to accrue or arise in India [Export commission to foreign agent] - Assessment year 2008-09 - Whether, export commission paid to foreign agent for procuring order and pursuing payment from foreign buyer did not accrue or arise in India as no services were rendered in India - Held, yes [2013] 37 taxmann.com 135 (Delhi - Trib.) IN THE ITAT DELHI BENCH 'A' Allied Nippon Ltd. v. Deputy Commissioner of Income-tax, Circle-1(1), New Delhi

Q When the agents of an airline had been given discretion to sell tickets at any rate between fixed minimum commercial price and published price, whether the amount which agent earned over and above fixed minimum commercial price would amount to commission or brokerage and liable for tax deduction u/s 194H ?
Answer:No, Section 194H of the Income-tax Act, 1961 - Deduction of tax at source - Commission or brokerage etc. - Where agents of an airline had been given discretion to sell tickets at any rate between fixed minimum commercial price and published price, amount which agent earned over and above fixed minimum commercial price would neither amount to commission nor brokerage at hands of agent, and, therefore, tax at source was not deductible on that amount under section 194H [In favour of assessee] [2012] 20 taxmann.com 598 (Bom.) HIGH COURT OF BOMBAY
Commissioner of Income-tax v. Qatar Airways

Q Whether Trade discount given by newspaper agencies to advertising agencies working for advertisers, is in nature of 'commission' as per provisions of Explanation (i) to section 194H invoking TDS obligation of newspaper ?
 Answer No,  Section 194H of the Income-tax Act, 1961 - Deduction of tax at source - Commission or brokerage, etc. - Assessment years 2009-10 and 2010-11 - Assessee, printing and publishing newspapers, was giving trade discount to advertising agencies - There was no control of assessee on advertising agencies in case of a relationship of any principal and its agent, where principal retains full control over activities of agent - In fact advertising agencies were working for advertisers/clients and not on behalf of assessee-company - Further, it was advertising agency which was responsible for payment to assessee even if advertiser had not paid amount to advertising agency - Whether no foundational fact existed on basis of which any inference could be drawn that advertising agencies were agent of assessee and, further, that advertising agencies rendered any service to newspaper - Held, yes - Whether, therefore, no proceedings could be initiated under sections 201/201(1A) - Held, yes [In favour of assessee]
[2012] 21 taxmann.com 489 (All.) HIGH COURT OF ALLAHABAD
Jagran Prakashan Ltd. v. Deputy Commissioner of Income-tax (TDS)
  







No comments:

Post a Comment