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2013 (12) TMI 831 - HC - Income TaxDisallowance u/s 40(a)(ia) for non deduction of TDS - payments have been artificially broken up to avoid the TDS provisions - composite contract - Held that:- it is not clear that which portion of the payment was made for infrastructural facilities. But, whatever may be the position, the payment has been made and the tax could have been deducted at source. In view of the fact finding of the learned Tribunal, we are unable to admit the appeal, as the learned Tribunal has correctly held that the assessee has not deducted the tax at source from the payment made to M/s. Ushakiran Movies Limited and therefore, the disallowance made under Section 40(a)(ia) was justified. - Decided against the assessee.
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