https://www.taxtmi.com/caselaws?id=777250 ITAT upheld additions under s.40(a)(ia) for failure to deduct TDS under s.194C and dismissed the appeals. The tribunal found the assessee failed to prove payments were mere reimbursements and had not obtained a certificate under ss.197/197A authorizing non-deduction or lower deduction. It held that s.194C does not permit bifurcation of the contract sum and that the second proviso to s.40(a)(ia) was inapplicable on the facts. Consistency arguments failed for lack of identical factual foundation. en-us Fri, 22 Aug 2025 00:00:00 +0530 Wed, 27 Aug 2025 08:41:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777250 ITAT upheld additions under s.40(a)(ia) for failure to deduct TDS under s.194C and dismissed the appeals. The tribunal found the assessee failed to prove payments were mere reimbursements and had not obtained a certificate under ss.197/197A authorizing non-deduction or lower deduction. It held that s.194C does not permit bifurcation of the contract sum and that the second proviso to s.40(a)(ia) was inapplicable on the facts. Consistency arguments failed for lack of identical factual foundation. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777250