2022 (2) TMI 325

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....s of appeal, the assessee has challenged various observations and findings of Ld. Pr. CIT in his revisionary jurisdiction u/s. 263, setting aside the assessment order dated 12.02.2016 passed under Section 144C read with section 143(3) of the act. 3. Before us the ld. Sr. Counsel Mr. Ajay Vohra for the assessee submitted that the ld. Pr. CIT has set aside the assessment order, firstly, on the issue of provision for warranty to re-examine its allowability as revenue expenditure; and secondly, on disallowance under Section 40(a)(ia) of the Act. He pointed out that, in so far as issue of disallowance under Section 40(a) (ia) of the Act, the ld. AO in the set aside proceedings after verification has decided this issue in favour of the assesse....

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.... claimed by the assessee for purchase of raw material and applicability of Section 40(a)(ia) of the Act. In so far as the issue of disallowance under Section 40(a)(ia), the ld. Pr. CIT directed the Assessing Officer to verify, whether the provision of Section 194C(3) of the Act is applicable and whether the assessee has excluded the value or not. Now as pointed out by the ld. Sr. Counsel, the ld. Assessing Officer vide order dated 29.12.2018 passed in pursuance of order under Section 263 of the Act, has given a finding that assessee has produced the copies of details of TDS certificate and details of suppliers and also the material which were not supplied to the assessee. AO found that the assessee had deducted TDS on the expenses as mandat....