https://www.taxtmi.com/caselaws?id=456934 The ITAT Raipur upheld the disallowance under Section 40(a)(ia) for interest payments made to NBFCs without TDS deduction under Section 194A. The assessee claimed the payee companies had included interest income in their returns and paid taxes, but failed to substantiate this with required certificates in Form 26A read with Section 31ACB. The assessee could not produce evidence that payees fulfilled conditions under the first proviso to Section 201(1) and admitted during hearing that necessary certificates were never obtained. The tribunal found no infirmity in lower authorities' decision as mandatory conditions under the second proviso to Section 40(a)(ia) were not satisfied. en-us Thu, 03 Aug 2023 00:00:00 +0530 Tue, 27 Aug 2024 14:09:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456934 The ITAT Raipur upheld the disallowance under Section 40(a)(ia) for interest payments made to NBFCs without TDS deduction under Section 194A. The assessee claimed the payee companies had included interest income in their returns and paid taxes, but failed to substantiate this with required certificates in Form 26A read with Section 31ACB. The assessee could not produce evidence that payees fulfilled conditions under the first proviso to Section 201(1) and admitted during hearing that necessary certificates were never obtained. The tribunal found no infirmity in lower authorities' decision as mandatory conditions under the second proviso to Section 40(a)(ia) were not satisfied. Case-Laws Income Tax Thu, 03 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456934