2022 (5) TMI 1178

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....ated in brief. The assessment in the hands of the assessee for the year under consideration was completed under section 143(3) of the Act on 10.02.2016. Subsequently, the AO initiated rectification proceedings under section 154 of the Act. The reasons for initiation of rectification proceedings are stated as under by the AO in the rectification order: "The LAP Audit has raised objection on 21.03.2017 stating that "the assessee has debited Rs. 38,40,334/-towards Professional and consultancy charges paid and Rs. 1,90,427/- towards advertisement charges paid in the P&L account and TDS on these expenses liable to be deducted is Rs. 3,84,033/- and Rs, 19,043/- respectivily. As per the Anexure VII forming part of Form 3CD, Col. 27(b), the asses....

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....ssee had deducted tax at source from the amount of Rs.33.39 lakhs. The assessee was not liable to deduct tax at source from the balance amount of Rs.5.01 lakhs, as the payment made to each of the parties was less than the threshold limit prescribed in sec.194J of the Act. Inviting my attention to page 14 of the Paper Book, the Ld AR submitted that the breakup details of payments made to various persons, the details of tax deducted at source and the details of payment which are not liable for TDS were furnished to the AO in the form of a statement during the course of assessment proceedings. The AO has accepted the factual position after examining the statement. With regard to the advertisement expenses, the Ld AR submitted that the assessee....