Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
TDS u/s 194H - non deduction of TDS commission paid to Primary Agriculture Co-operative Society (PACS) The Tribunal analyzed guidelines issued by the State Government and concluded that PACS functioned as agents of the State Government. Therefore, the commission paid by the assessee to PACS was subject to deduction of tax at source under section 194H of the Act. It was observed that the assessing officer had calculated TDS at the maximum rate without considering relevant factors such as the availability of PAN for PACS. Hence, the matter was remanded back to the assessing officer for proper verification and calculation of TDS.
TDS u/s 194H - non deduction of TDS commission paid to Primary Agriculture Co-operative Society (PACS) The Tribunal analyzed guidelines issued by the State Government and concluded that PACS functioned as agents of the State Government. Therefore, the commission paid by the assessee to PACS was subject to deduction of tax at source under section 194H of the Act. It was observed that the assessing officer had calculated TDS at the maximum rate without considering relevant factors such as the availability of PAN for PACS. Hence, the matter was remanded back to the assessing officer for proper verification and calculation of TDS.
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