https://www.taxtmi.com/caselaws?id=180256 The Tribunal found the relationship between the assessee and the consolidator to be on a principal-to-principal basis, similar to the precedent set in 'Finian Estates Developers (P) Ltd.' As a result, Sections 194C or 194H were deemed inapplicable, and no disallowance under Section 40(a)(ia) was justified. Additionally, since the purchases were part of the closing stock and no sales occurred during the year, the disallowance did not impact taxable profits. Consequently, the Tribunal allowed both appeals, overturning the disallowance imposed by the Assessing Officer and upheld by the CIT (A). en-us Fri, 12 Apr 2013 00:00:00 +0530 Fri, 19 May 2017 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180256 The Tribunal found the relationship between the assessee and the consolidator to be on a principal-to-principal basis, similar to the precedent set in 'Finian Estates Developers (P) Ltd.' As a result, Sections 194C or 194H were deemed inapplicable, and no disallowance under Section 40(a)(ia) was justified. Additionally, since the purchases were part of the closing stock and no sales occurred during the year, the disallowance did not impact taxable profits. Consequently, the Tribunal allowed both appeals, overturning the disallowance imposed by the Assessing Officer and upheld by the CIT (A). Case-Laws Income Tax Fri, 12 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180256