Disallowance of expenses where TDS has not been deducted u/s 40(a)(ia)

[RAMESH MANSHARAMANI]

one of my client who is proprietor of his firm and his case was selected for scrutiny for the asst. year 2007-2008 and ITO concludes that no tds deducted on respective expenses so whole expenditure, which direcly relates to the product of the business, disallowed u/s. 40(a)(ia) of the Income Tax Act now i filed appeal before CIT in which mentioned that assessee has carried out work from various labourer who has having specialised skilled and assessee has not deducted TDS on paid amount which cross the specified limit of no deduction during the year I need your guidence particularly to narrate relevant case law in my submission which is to be submitted before CIT (A) CA RAMESH K M [email protected]

AI Summary

Proprietor Challenges Disallowance Under Section 40(a)(ia) for Non-Deduction of TDS in 2007-2008 Assessment Year Appeal A client, a proprietor, faced scrutiny for the assessment year 2007-2008 due to non-deduction of TDS on certain business expenses, leading to disallowance under Section 40(a)(ia) of the Income Tax Act. An appeal was filed before the CIT, arguing that the work was performed by skilled laborers, and no TDS was deducted as the amount exceeded the specified limit. The reply suggested arguing that no tax was deductible, payments were allowable under different sections, payees could provide certification for non-taxable income, and exploring other relevant grounds. The discussion sought guidance on relevant case law for the appeal.