TaxTMI 
TaxTMI 
2025 (5) TMI 1958
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....as raised following grounds of appeal : "1. The Ld. CPC erred in disallowing Rs. 18,48,488/- u/s 40(a)(i) of the IT ACT. 2. The Ld. CIT-A ought to have considered the fact that the no withholding tax is required to be deducted on payment made to M/s UL LLC and CSA Group Testing & Certification INC and therefore no disallowance u/s 40(a)(i) is required to be made 3. The Ld. CIT-A erred in misinterpreting that issue relating to Disallowance u/s 40(a)(i) is discussed by AO and accepted, whereas AO has discussed this issue but did not accept. AO while passing the order u/s 143(3), has started with "Assessed income u/s 143(1)" of the IT Act." 3. With the assistance of both the sides and also on perusal of the records including the paper b....
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....ssessee's contentions, ld.CIT(A) dismissed the ground for statistical purposes. 4. Now the assessee has preferred this appeal against the said finding of ld.CIT(A) dismissing the grounds raised by the assessee as dismissed for statistical purposes. 5. Ld. Counsel for the assessee referring various documents filed in the paper book again contended that TRC certificate has been filed along with Form 15CB as well as PE Certificate and India Office undertaking document to demonstrate that tax was not required to be deducted on the alleged payment. He also submitted that ld. AO has himself accepted the assessee's contentions and the scrutiny proceedings which were carried out after the processing of return u/s. 143(1)(a) of the Act, therefore ....
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....dition made u/s. 40(a)(i) of the Act. Necessary discussion made by the AO in the assessment order reads as under : "Assessee has made the contention that payments made to Canadian Standard Association and UL LLC are not covered under 40(a)(i) payments. As per assessee CSA Group tests and certifies many global leading brands to help comply with applicable U.S. and Canadian standards written by ANSI, ASME, ASSE, ASTM, ASFE, UL, CSA, NSF, and more. CSA's safety, electromagnetic compatibility (EMC), and energy efficiency verification (EEV) laboratories are located around the world and accredited internationally. Thus, we approached to CSA for certification of our products as per international standards so that our product gets required ....