2020 (1) TMI 148

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....r dated 12.6.2019 for the assessment year 2011-12. 2. The sole ground raised by the assessee is that the ld CIT(A) is not justified in confirming the addition of Rs. 5,00,000/- made u/s.40(a)(ia) of the Act. 3. Ld A.R. of the assessee submitted that non-deduction of TDS while making deposit to transporter providers on declaration of PAN Number which came into effect from 1.10.2009. ld A.R. furth....

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.....R. submitted that in pursuance to the order of Pr. CIT, Bhubaneswar u/s.263 of the Act dated 14.3.2016, the AO was directed to frame denovo assessment order and in pursuance thereto, the Assessing Officer passed reassessment order u/s.263/143(3) on 23.12.2016. Ld D.R. submitted that on the date of passing order, the amendment inserted by the legislature was operative and effective and, therefore,....

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.... its wisdom added words "where such contractor owns ten or less goods carriage at any time during the previous year and furnishes a declaration to that effect along with". In my humble understanding, the purpose of insertion of said provisions of sub-section(6) to section 194C was that the legislature in its wisdom wanted to give relaxation of this provision only in a case where the contractor own....