2025 (8) TMI 1861

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.... Maity, Adv. For the Department : Sh. Jitender Singh, CIT(DR) ORDER PER SATBEER SINGH GODARA, J.M: These Revenue's twin appeals ITA Nos. 24 & 28/Del/2025 for A.Y. 2014-15 & 2015-16 arise against Commissioner of Income-tax (Appeals)-31, New Delhi's as many orders; both dated 18.10.2024 passed in case nos. CIT(A), Delhi NFAC/2013-14/10042216 & CIT(A), Delhi-NFAC/2014-15/10149338, respect....

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...., the Ld. CIT(A) failed to appreciate the facts of the case judiciously that External Development Charges (EDC) paid by deductor company to HUDA are liable for deduction of TDS u/s.194C of the Income Tax Act, 1961. 3. On the facts and in the circumstances of the case and in light of judgment of the Hon'ble jurisdictional High Court, Delhi in the case of M/s Puri Construction Private L....

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....'s findings, treating the assessee as not the assessee in default u/s 201(1A) of the Act for not having deducted TDS on external development charges "EDC" payments made to the Haryana Urban Development Authority (HUDA) involving varying sums in. This being the clinching factual position, the assessee could hardly dispute that the hon'ble jurisdictional high court's landmark decision in M/s Puri Co....