2025 (3) TMI 596

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.... JCIT For the Respondent : Mr. S.Ananthan, C.A. And Ms. Lalitha Rameswaran, CA ORDER PER GEORGE GEORGE K, VICE PRESIDENT: This appeal at the instance of the Department is directed against CIT(A) - NFAC order dated 14.10.2024, passed under section 250 of the Income Tax Act, 1961 (hereinafter called 'the Act'). The relevant Assessment Year is 2010-11 2. The grounds raised are read as ....

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....- The reassessment was completed u/s. 143(3) r.w.s 147 of the Act vide order dated 23.03.2016. In the said reassessment order, AO had disallowed interest payment of Rs. 1,35,56,446/- u/s. 40(a)(ia) of the Act for not deducting tax at source. 4. Aggrieved by the order of AO, assessee preferred appeal before First Appellate Authority. The CIT(A) following the ITAT order in assessee's own case ....

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....or non deduction of TDS thereon. The Id. CIT (A) had referred to the relevant provisions of Section 194A of the Act and amendment made by Finance Act, 2015. The decision of the Id. CIT(A) is based on proper appreciation of the legal position. Accordingly, we do not find any merits in the ground No.7 raised by the Revenue. Ground No.7 of the Revenue is dismissed." 8. In the instant case, since a....