2020 (9) TMI 867

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....T-455 to 457/2017-18 dated 07/02/2019. The facts as well as dispute is stated to be pari-materia the same in all the 3 years. 1.2 We have heard the rival submissions and perused relevant material on record including documents placed in the paper-book. Our adjudication to the subject matter of appeals would be as given in succeeding paragraphs. First, we take up appeal for AY 2006-07. ITA No. 2411/Mum/2019, AY 2006-07 2.1 The grounds raised by assessee are as follows: - The Learned Commissioner of Income Tax Appeals-59 disallowed ground no.4 of Appeals without considering the explanation submitted for determination of correct nature of expense to determine the rate of TDS. The learned Commissioner Appeals treated the explanation ....

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....i) Web Synergy; (iii) Shrinagar Films Pvt. Ltd.; (iv) Shyam Film Transfer Services & (v) Sagarika Acoustronics Pvt. Ltd. 2.5 The workings of short-deduction of TDS as worked out by Ld. AO aggregated to Rs. 61,317/- which would attract consequential interest of Rs. 49,317/- u/s 201(1A). Thus, a demand of Rs. 1,10,634/- was raised against the assessee. 3. Before Ld. CIT(A), the assessee submitted party-wise details and pleaded no default. However, Ld.CIT(A) refused to admit the additional evidences filed u/r 46A since the assessee, in the opinion of Ld. CIT(A), failed to demonstrate sufficient cause for admission of the same. Consequently, the demand raised against the assessee was upheld. Aggrieved, the assessee is in further app....