https://www.taxtmi.com/caselaws?id=450835 The ITAT Delhi allowed the assessee's appeal regarding TDS disallowance under section 40(a)(ia). Despite TDS being correctly deducted at applicable rates with proper lower deduction certificates obtained, authorities disallowed the expenditure solely because section 194IB was mentioned instead of section 194I(b). The tribunal held this technical error insufficient to sustain the disallowance when substantive compliance was evident. However, the tribunal dismissed the assessee's claim for excess Dividend Distribution Tax refund, following precedent that DTAA protection doesn't automatically apply to domestic companies paying DDT under section 115O unless contracting states specifically extend such protection. en-us Tue, 12 Mar 2024 00:00:00 +0530 Thu, 14 Mar 2024 07:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450835 The ITAT Delhi allowed the assessee's appeal regarding TDS disallowance under section 40(a)(ia). Despite TDS being correctly deducted at applicable rates with proper lower deduction certificates obtained, authorities disallowed the expenditure solely because section 194IB was mentioned instead of section 194I(b). The tribunal held this technical error insufficient to sustain the disallowance when substantive compliance was evident. However, the tribunal dismissed the assessee's claim for excess Dividend Distribution Tax refund, following precedent that DTAA protection doesn't automatically apply to domestic companies paying DDT under section 115O unless contracting states specifically extend such protection. Case-Laws Income Tax Tue, 12 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450835