2020 (1) TMI 148

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....nst the order of the CIT(A),1, Bhubaneswar 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 c....

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....ete the addition. 4. Replying to above, ld D.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 legislat....

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.... of section 194C of the Act as the legislature in 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 ....