2022 (6) TMI 1345

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....e Tax<br>Om Prakash Kant, Accountant Member And Shri Rahul Chaudhary, Judicial Member For the Appellant : Shri RV Shah. For the Respondent : Shri C.T. Mathews. ORDER Per Rahul Chaudhary, Judicial Member : 1. These Miscellaneous Applications have been filed by the Assessee for rectification of common order, dated 31.05.2019, passed by the "B" Bench of the Tribunal in three appeals, b....

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.... first deductible to the date of filing of relevant return of income by the recipient-deductee. The appeals filed by the Assessee was disposed of by way of common order dated 31.05.2019 which is now sought to be rectified by way of present the applications. MA No. 63/Mum/2020 3. Before us, Ld. Authorised Representative for the Assessee referred to paragraph 3 of the application and after mak....

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....8223;] under Section 201(1A) of the Income Tax Act, 1961 (hereinafter referred to as "the Act&#8223;) on the ground that the Assessee had no liability to withhold tax and therefore, provisions of Section 201(1A) are not attracted. Having perused the material on record, and the order dated 31.05.2019 passed by the Tribunal, we find merit in the contention of the Assessee that Ground No. 1, 1.1, and....