2019 (8) TMI 642

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....e Income Tax Act, 1961 (hereinafter referred to as "the Act") in their respective cases. These appeals pertain to assessment years 2009-10 and 2010-11 as mentioned in the memo of parties against the respective title of appeal. Since, the issue raised in all these bunch of appeals is identical, these appeals are taken up together for adjudication and are disposed of vide this common order. 2. Shri A.V. Iyer appearing on behalf of the assessee submitted that the Department sought information relating to Tax Deducted at Source (TDS) on interest payments to its customers from various branches of the assessee bank located in Pune and Solapur. The ld. AR submitted that out of total 53 appeals, 21 appeals pertain to assessment year 2009-10. ....

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.... of data to be searched for furnishing the information was huge. The assessee tried it level best to retrieve the information / documents as far as possible and submitted the same before the Assessing Officer within the period of two weeks time. The assessee inter alia furnished following documents : i. Certificate of Nil/lower deduction of tax in respect of some deposit holders. ii. Income Tax returns of various depositors wherein the bank failed to deduct TDS but the depositors have fully disclosed interest received from the bank and have paid taxes thereon. iii. Details of the depositors wherein interest was paid on maturity but no tax at source was deductable. 2.3 The ld. AR submitted that though effort was....

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....imitation for passing the orders u/s. 201(1) was two years from the end of financial year in which the statement is filed and six years from the end of financial year in which the payment is made or is credited. The case of assessee in all the appeals fails under sub-section 3(i) of section 201 of the Act. 3. On the other hand Shri A.K. Modi and Shri Rajesh Gawali representing the Department vehemently defended the impugned orders. The ld. DRs submitted that sufficient opportunity of hearing was afforded to the assessee by the Commissioner of Income Tax (Appeals) and the Assessing Officer. However, the assessee failed to produce relevant documents to support its contentions. The ld. DRs filed a chart indicating date of show cause n....