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Income Tax Commissioner's Revision u/s 263 Deemed Invalid for Disallowance u/s 40(a)(ia) on TDS Non-Deduction.

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....Revision u/s 263 by CIT - Disallowance u/s 40(a)(ia) - Applicability of TDS on payment of commission, labour charges and advertisement - The amounts referred under three Heads do not require deduction of any TDS and in this situation, no disallowance u/s 40(a)(ia) is called for. Commissioner has failed to examine the issue analytically in right perspective and, therefore, it is not sustainable in the eyes of law. - AT....