2026 (9) TMI 136

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....the Appellant : Shri Subash Agarwal, Advocate For the Respondent : Shri Manoj Kumar, Sr. DR ORDER PER VIKAS AWASTHY, JUDICIAL MEMBER : This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-30, New Delhi [in short 'the CIT(A)'] dated 14.02.2026, for Assessment Year 2015-16. 2. The solitary issue raised by the assessee in appeal is against t....

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....the following decision of the Tribunal to contend that on payment of EDC there is no liability to deduct tax at source. Accordingly, the assessee cannot be treated as assessee in default in terms of section 201(1) of the Act: ACIT vs. Shree Vardhaman Developers (P) Ltd. in ITA No.2366-2367/Del/2023 for AY 2019-2020 & 2020-21 decided on 21.12.2023; M/s. Santur Infrastructure P. Lt....

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....hikaran (HSVP), the assessee is liable to deduct tax at source u/s. 194C of the Act. HSVP neither falls within the ambit of clause (i) or clause (iii) of section 196 of the Act. The mere fact that HSVP has been constituted under statutory enactment does not make it the 'Government'. Even, if, it is discharging functions akin to Governmental obligations or performing activities closely connected wi....