2018 (11) TMI 1944

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.... This is Revenue's appeal for the Assessment Year 2011-12 against the order of the CIT(A)-4, Hyderabad dated 13.03.2015. The Revenue has raised the following grounds of appeal: "1. Whether in the facts and circumstances of the case, the Ld. CIT(A) is correct in deleting the disallowance. 2. The Ld. CIT(A) has failed to note that the objective of forming the assessee JV is not merely for the pu....

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....ish the details of TDS made and remitted to Government Account. Assessee furnished the details as per which the TDS was effected only on Rs. 17,80,48,272/- and the balance of Rs. 29,80,87,479/- had not suffered TDS. When the assessee was asked to show cause as to why the disallowance u/s 40(a)(ia) shall not be made on the balance of Rs. 29,80,87,479/-, the assessee submitted that the Joint Venture....

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....esentative supported the orders of the authorities below while the Learned Counsel for the Assessee supported the order of the CIT(A) and also field copy of the decision of the ITAT in the assessee's own case for the A.Y. 2010-11. He has also filed a copy of the Department of Company Affairs, Circular No.1-81 (20-1-81-CL-V) dated 14.09.1981 wherein it was clarified that the companies can enter int....