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    <title>2020 (11) TMI 204 - ITAT PUNE</title>
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    <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the CIT(A)&#039;s decision to delete the disallowance under section 40(a)(ia) of the Act for the assessment year 2014-15. The Tribunal found that the joint venture, as an AOP, was not in default since the payee had disclosed and offered the income for taxation. The decision was consistent with previous Tribunal rulings favoring the assessee, emphasizing that the strict application of section 40(a)(ia) was unwarranted in this context. The Tribunal referenced decisions from the Delhi HC and Co-ordinate Bench, reinforcing the conclusion that the assessee was not liable for TDS disallowance.</description>
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      <link>https://www.taxtmi.com/caselaws?id=400449</link>
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