2023 (1) TMI 848

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..... For the Respondent : Shri Gireesh Kumar, Sr.DR ORDER PER PRADIP KUMAR KEDIA, A.M.: The captioned appeal has been filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-XXXI, New Delhi ['CIT(A)' in short] dated 12.02.2019 arising from the assessment order dated 09.10.2014 passed by the Assessing Officer (AO) under Section 200A(1) of the Income Tax Act, 1961....

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....ion certificate was issued under Section 197 to the holding company of the assessee. Due to the inadvertent mistake in quoting TAN of different unit, the Assessing Officer created a demand u/s.200A alleging lesser deduction of tax on payments made to holding company. 3. Aggrieved by the demand raised under Section 200A of the Act, the assessee preferred appeal before the CIT(A). The CIT(A) took....

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....ant company has two TANs, one for Delhi office and other for Bina office. The appellant company got executed the toll road project situated at Bina Kurwaj Sironj Toll Road (MP) through its subsidiary company Telecommunication Consultants India Ltd which obtained a Lowe Deduction Certificate at 0.25% dated 01.08.2013 from DCIT, TDS Circle051(1), Delhi in respect of various deductors including the a....

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....ucceeds partly." 4. On perusal of the first appellate order and the factual matrix pointed out on behalf of the assessee, we find that the order of the CIT(A) in granting relief to the assessee is founded on fair play and natural justice. In the instant case, the assessee has obtained two TAN from the Department in its name, one is taken for office at Bina Madhya Pradesh and another one is take....