https://www.taxtmi.com/caselaws?id=751172 ITAT Ahmedabad allowed assessee's application u/s 154 seeking rectification for benefit of second proviso to Section 40(a)(ia) regarding disallowance on payments made without TDS deduction. The tribunal held that the second proviso has retrospective effect based on jurisdictional HC decision in Arvind Lifestyle Brands Ltd., making it applicable to AY 2005-06. The denial of this benefit constituted a mistake apparent from record. The application was maintainable u/s 154 and the matter was restored to AO for considering quantum of benefit allowable under the second proviso. en-us Fri, 05 Apr 2024 00:00:00 +0530 Tue, 09 Apr 2024 08:25:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751172 ITAT Ahmedabad allowed assessee's application u/s 154 seeking rectification for benefit of second proviso to Section 40(a)(ia) regarding disallowance on payments made without TDS deduction. The tribunal held that the second proviso has retrospective effect based on jurisdictional HC decision in Arvind Lifestyle Brands Ltd., making it applicable to AY 2005-06. The denial of this benefit constituted a mistake apparent from record. The application was maintainable u/s 154 and the matter was restored to AO for considering quantum of benefit allowable under the second proviso. Case-Laws Income Tax Fri, 05 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751172