2025 (5) TMI 2223

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.... The impugned order was emanated from the order of the Ld. Income-tax Officer (TDS) (OSD), Circle 2(3), Mumbai, (in short, 'the A.O.') passed under section passed under section 201 (1) / 201(1A) of the Act, date of order 21/03/2023. 2. The revenue has taken the following grounds of appeal:- "I hereby direct the DCIT (TDS)-2(3), Mumbai, to file an appeal to the Appellate Tribunal, Mumbai against the order of No. ITBA/APL/S/250/2024- 25/1072618951(1) dated 28.01.2025, in the above case on the following ground(s): 1. "On the facts and in the circumstances of the case and law, the Id. CIT(A) has erred in holding that the transaction of sale between the assessee company and stockiest was on principal to principal basis and t....

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....e found and accordingly, the assessee's case was taken for scrutiny. After the scrutiny, finally the Assessing Officer a tax liability of Rs. 53,60,41,868/- was determined, being tax of Rs. 28,11,99,937/- under section 201(1) and interest of Rs. 25,48,41,931/- under section 201(1A) in an order passed section 201(1) and interest under section 201(1A) totalling was determined. The aggrieved assessee filed an appeal before the CIT(A). The Ld. CIT(A) partly allowed the appeal by holding that the assessee will not be treated as liable to pay any interest on non-deduction of TDS as there is no liability in the first place to deduct TDS for the assessment year under consideration. Being aggrieved on the appeal order, the revenue filed an appeal be....