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The HC upheld the ITAT's decision deleting the addition under section 40(a)(ia) for short deduction of TDS under sections 194C and 194J. The court affirmed that section 40(a)(ia) is inapplicable to cases of short deduction, thereby negating the revenue's claim for disallowance. The ruling relied on precedent favoring the assessee where conflicting views exist among non-jurisdictional High Courts on the issue. Consequently, the HC found no error in the ITAT's order and dismissed the revenue's appeal, confirming that short deduction of TDS does not warrant disallowance under section 40(a)(ia).
The HC upheld the ITAT's decision deleting the addition under section 40(a)(ia) for short deduction of TDS under sections 194C and 194J. The court affirmed that section 40(a)(ia) is inapplicable to cases of short deduction, thereby negating the revenue's claim for disallowance. The ruling relied on precedent favoring the assessee where conflicting views exist among non-jurisdictional High Courts on the issue. Consequently, the HC found no error in the ITAT's order and dismissed the revenue's appeal, confirming that short deduction of TDS does not warrant disallowance under section 40(a)(ia).
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