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    <title>2014 (4) TMI 1137 - ITAT AMRITSAR</title>
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    <description>Section 40(a)(ia) was applied as a deeming disallowance where tax deductible under Chapter XVII-B had not been deducted, even though the assessee claimed exemption under section 10(20) and argued that the receipt was not business income. The Tribunal treated the composite contract for supply, erection, testing and commissioning as attracting TDS under section 194C, and held that the exemption claim did not neutralise the statutory consequence of non-deduction. It further held that section 40(a)(ia) is not limited to amounts outstanding at year-end; it also covers expenditure already paid during the year if tax was deductible but not deducted. The disallowance was therefore sustained.</description>
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    <pubDate>Tue, 29 Apr 2014 00:00:00 +0530</pubDate>
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      <title>2014 (4) TMI 1137 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=183387</link>
      <description>Section 40(a)(ia) was applied as a deeming disallowance where tax deductible under Chapter XVII-B had not been deducted, even though the assessee claimed exemption under section 10(20) and argued that the receipt was not business income. The Tribunal treated the composite contract for supply, erection, testing and commissioning as attracting TDS under section 194C, and held that the exemption claim did not neutralise the statutory consequence of non-deduction. It further held that section 40(a)(ia) is not limited to amounts outstanding at year-end; it also covers expenditure already paid during the year if tax was deductible but not deducted. The disallowance was therefore sustained.</description>
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      <pubDate>Tue, 29 Apr 2014 00:00:00 +0530</pubDate>
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