Dispute on TDS Deduction for Accommodation Perquisites: CIT(A) Upheld Despite Misclassification of Assessee Status.

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....TDS u/s 192 - failure to deduct TDS on the perquisite value of accommodation - though Ld. CIT(A) has fallen in error in holding that assessee falls in status of Central Government for the purpose of Section 17(2) of the Act, the impugned order of Ld. CIT(A) still deserves to be upheld as Ld. AO has fallen in error by straightaway invoking Rule 3 for computing value of the perquisite and treat assessee in default in deducting tax at source on said value, without first recording a finding as to whether there is 'concession' and the case is covered by Section 17 (2) (ii) of the Act. - AT....