2015 (9) TMI 1679

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....l Member Department by: Shri Ajay Modi Assessee by: Shri Porus Kaka, Shri Divesh Chawla ORDER N.K. Billaiya, 1. These are appeals by the Revenue and the Cross objections by the assessee against the very same order of the Ld. CIT(A), Mumbai dated 30.11.2011 pertaining to assessment years 2008-09 and 200910. Both these appeals and cross objections were heard together as they involved ....

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....lief that provisions of Sec. 194J squarely apply on the impugned payments made by the assessee and on his belief, the Officer levied interest u/s. 201(1A) of the Act which was challenged by the assessee before the Ld. CIT(A). 4. Before the First Appellate Authority, relying upon various judicial decisions in favour of the assessee, it was strongly contended that the payments made by the assesse....

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....k. The Ld. Counsel drew our attention to the decision of the Tribunal in assessee's own case in ITA Nos. 1413 & 1414/M/2014. The Ld. Counsel pointed out that in that case the dispute before the Tribunal was whether the Revenue authorities were justified in making the disallowance made on account of Channel placement fees u/s. 40a(ia) of the Act as TDS was not deducted u/s. 194J of the Act. We find....