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ITAT dismissed the appeals and upheld additions under section 40(a)(ia) consequent to non-deduction of TDS under section 194C. The Tribunal held the appellant failed to discharge the onus of proving payments were mere reimbursements and the respondent payee had not procured any certificate under sections 197/197A authorising no or lower deduction. The Tribunal ruled that section 194C does not permit contractual bifurcation of the gross sum and that the second proviso to section 40(a)(ia) did not assist the appellant on the facts. Consistency principles were rejected for lack of identical factual foundation; therefore the additions were sustained and appeals dismissed.
ITAT dismissed the appeals and upheld additions under section 40(a)(ia) consequent to non-deduction of TDS under section 194C. The Tribunal held the appellant failed to discharge the onus of proving payments were mere reimbursements and the respondent payee had not procured any certificate under sections 197/197A authorising no or lower deduction. The Tribunal ruled that section 194C does not permit contractual bifurcation of the gross sum and that the second proviso to section 40(a)(ia) did not assist the appellant on the facts. Consistency principles were rejected for lack of identical factual foundation; therefore the additions were sustained and appeals dismissed.
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