https://www.taxtmi.com/caselaws?id=465811 Disallowance under s. 40(a)(ia) for alleged failure to deduct TDS under s. 194C on procurement of specific packing material turned on whether the transaction was a works contract or a sale. The ITAT held that the assessee had not supplied raw material and the invoices evidenced outright purchase of goods subjected to indirect tax, not job work; hence s. 194C was inapplicable and the disallowance was unsustainable, resulting in dismissal of the Revenue's appeal. Deduction under s. 80P(2)(d) on dividend income was denied solely because the AO treated the assessee as a firm based on PAN particulars. The ITAT held registration and supporting evidence were not rebutted, directed the AO to verify other statutory conditions and allow the claim per law; the cross-objection was allowed for statistical purposes. en-us Mon, 27 Jan 2025 00:00:00 +0530 Fri, 09 Jan 2026 19:03:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465811 Disallowance under s. 40(a)(ia) for alleged failure to deduct TDS under s. 194C on procurement of specific packing material turned on whether the transaction was a works contract or a sale. The ITAT held that the assessee had not supplied raw material and the invoices evidenced outright purchase of goods subjected to indirect tax, not job work; hence s. 194C was inapplicable and the disallowance was unsustainable, resulting in dismissal of the Revenue's appeal. Deduction under s. 80P(2)(d) on dividend income was denied solely because the AO treated the assessee as a firm based on PAN particulars. The ITAT held registration and supporting evidence were not rebutted, directed the AO to verify other statutory conditions and allow the claim per law; the cross-objection was allowed for statistical purposes. Case-Laws Income Tax Mon, 27 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465811