Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
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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