Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
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