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    <title>2020 (11) TMI 113 - ITAT DELHI</title>
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    <description>Amounts collected by a utility as a statutory agent of the Government are not the assessee&#039;s own liability for section 43B where the electricity duty is merely received from consumers and credited or adjusted in favour of the State; the disallowance was therefore not justified. Transmission and wheeling charges were also held outside the TDS provisions on the facts, so no disallowance could be made under section 40(a)(ia) for alleged failure to deduct tax at source. The assessee succeeded on both additions, and the Revenue&#039;s challenge failed.</description>
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      <title>2020 (11) TMI 113 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=400358</link>
      <description>Amounts collected by a utility as a statutory agent of the Government are not the assessee&#039;s own liability for section 43B where the electricity duty is merely received from consumers and credited or adjusted in favour of the State; the disallowance was therefore not justified. Transmission and wheeling charges were also held outside the TDS provisions on the facts, so no disallowance could be made under section 40(a)(ia) for alleged failure to deduct tax at source. The assessee succeeded on both additions, and the Revenue&#039;s challenge failed.</description>
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