2020 (9) TMI 976

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ounsel For the Respondent : Ms.Sumitha for Mr.R.Sivaraman JUDGMENT ( Delivered by DR. VINEET KOTHARI , J ) This Tax Case Appeal has been filed by the Revenue, calling in question the correctness of the order passed by the Income Tax Appellate Tribunal, 'B' Bench, Chennai, dated 20.1.2016 made in ITA No.2092/Mds/2015, for the Assessment Year 2005-2006, by raising the following substa....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the ITAT erred in not appreciating and ignoring the ratio of decision in the case of Ryatar Sahakari Sakkare Karkhane Niyamit v. CIT (2016) 67 taxmann.com 283 (Karnataka) wherein it is held that section 40(a)(ia) cannot be interpreted to mean that it applies only to amounts "payable" and not to those which have been "paid"? (iv) Whether on the facts and circumstances of the case and in law, th....