2017 (5) TMI 1705

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....hah-AR ORDER PER RAJENDRA, AM Challenging the order dated 30.01.2014 of CIT (Appeals)-31, Mumbai, the Assessee has filed the present appeal.Assessee,-firm filed its return of income on 03.03.2007,declaring total income at Rs. 24.29 lakhs. The Assessing Officer (A.O.) completed the assessment on 26. 12.2007 at Rs. 8.68 crores. He made disallowance 40(a)(ia) on account of late payment of TD....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....paid during the year under consideration or before the filing of the return,that as per the Circular no.10/DV/2013 dated 16.12.2013 issued by the CBDT the provisions of Section 40(a)(ia) would cover not only amounts as payable on last date of any previous year but also amounts which were payable at any time during the year, that the assessee had not furnished evidence of TDS payment with reference....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....owance made by the AO was not justified. The Departmental Representative (DR) stated that amendment to the section was prospective. He referred to the case of Thomas George Muthoot (235taxman246). In his rejoinder the AR argued that the amendment to section 40(a)(ia) in the year 2014 was introduced to reduce hardship caused to the assessee, that the Tribunal in the case of amruta Quarry Works(s....