2025 (8) TMI 192

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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 JCIT, Range-76, New Delhi dated 26.02.20....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 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 certain payees ; or applying wrong rate of deduction....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 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 passing a single consolidated order for various asse....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ng 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 undertaking having very qualified personnel. The lack of competen....