2025 (8) TMI 192

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....in, Advocate For The Respondent : Ms. Harpreet Kaur Hansra, Sr. DR ORDER PER M. BALAGANESH, AM: These appeals of the Assessee are arises out of the order of the Commissioner of Income Tax (Appeals)-30, Delhi [hereinafter referred to as 'CITA(A)'] in Ap. No.10508/2017-18 and Appeal No.10511/2017-18 for A.Y. 2010-11/2011-12 and 2013-14/2014-15 dated 10.01.2024 against the order passed by....

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....nces of the instant case. 5. We have heard the rival submissions and perused the relevant material available on record. It is not in dispute that the assessee company while filing its TDS returns on quarterly basis had made certain errors by either not mentioning the PAN of the payees; or not mentioning the lower tax deduction certificate obtained u/s.197 of the Act qua payments made to the cer....

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....for various assessment years for various quarters were confirmed by the learned CIT(A). 6. At the outset, we find that the deficiencies / errors committed by the assessee in the quarterly TDS returns were mere typographical errors and there is absolutely no contumacious conduct or malafide indent on the part of the assessee to defraud revenue. In any event, the learned AO was not justified in p....

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....ies below have been too rigid to expect an explanation overlooking the principles of human behavior, conduct and prudence. We are of the considered view that arithmetical and clerical mistakes are always likely to happen in accounting and reporting transactions to the Id. Tax authorities. No malice can be imputed on the basis that the mistake was a recurring one or that entity is a big corporate u....