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Tribunal Overlooks TDS Liability on IUC Payments, Remands Case Without Addressing Section 194C Applicability, AO to Re-examine.
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....Non adjudication of grounds by tribunal - Liability of TDS u/s 194C - Tribunal ought to have rendered a finding on the grounds raised by the assessee with regard to the applicability of Section 194C on the IUC paid to the other telecom operators and remanded on alternative ground - without any finding on the applicability of Section 194C the order passed by the Tribunal should be and shall be read as an open remand to the AO....