2025 (2) TMI 1437

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....p, Adv. For the Revenue : Sh. Rajesh Kumar Dhanesta, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal ITA No. 483/Del/2025 with it's stay application SA No. 82/Del/2025 for Assessment Year 2016-17, arises against the CIT(A)/NFAC, Delhi's DIN & order No. ITBA/NFAC/S/250/2024-25/1071999641(1) dated 08.01.2025, in proceedings u/s 271(1)(c) of the Income Tax A....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t the impugned penalty indeed pertains to the major issue of section 40(a)(ia) disallowance of Rs. 1,65,91,243/- which was made by the learned lower authorities on account of non-deduction of TDS on payments made to the assessee's US based associated enterprises. The Revenue's stand accordingly is that the assessee ought to have deducted TDS on the said payment(s) and it's default to this effect i....