Petition dismissed; petitioner allowed to submit detailed disclosures and documents for re-consideration; notices for 2019-23 may be adjudicated on me...
Confiscation and duty recovery quashed where licensing records show export obligation discharged; customs lacks jurisdiction absent licence annulment ...
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ITAT allowed the taxpayer's appeal against the Assessing Officer and CIT(A)'s treatment of the taxpayer as a defaulter under ss. 201(1)/201(1A) arising from TDS on commission payments to non-residents. The Tribunal held that the taxpayer produced requisite Form 15CBs for each non-resident remittance, applied the applicable DTAA positions, and deposited tax at source as required; accordingly there was no default under s. 201(1) r.w.s. 201(1A) or basis to sustain disallowances under s. 40(a)(i) r.w.s. 195. The impugned findings against the taxpayer were set aside and the appeal allowed.
ITAT allowed the taxpayer's appeal against the Assessing Officer and CIT(A)'s treatment of the taxpayer as a defaulter under ss. 201(1)/201(1A) arising from TDS on commission payments to non-residents. The Tribunal held that the taxpayer produced requisite Form 15CBs for each non-resident remittance, applied the applicable DTAA positions, and deposited tax at source as required; accordingly there was no default under s. 201(1) r.w.s. 201(1A) or basis to sustain disallowances under s. 40(a)(i) r.w.s. 195. The impugned findings against the taxpayer were set aside and the appeal allowed.
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