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2011 (12) TMI 584 - DELHI HIGH COURTTDS u/s 194C - Held that:- In the present case, the findings recorded by the CIT(Appeals) and Income Tax Appellate Tribunal are that the composite bills were not raised. The payments in question were towards the reimbursement of the exact amount which has been paid to the airlines towards freight charges. There is no finding that these agents deliberately separated/bifurcated the bills and service charges were independently paid or were included in the said bills. With regard to the second addition of ₹ 8,84,881/-, the concurrent findings recorded by the CIT(Appeals) and ITAT are that the said payments were less than ₹ 50,000/- to a single party and, therefore, TDS under Section 194C was not required to be deducted. The appellant has drawn our attention to the grounds of appeal in which it is stated that as per the books of accounts some of the parties were made payment of more than ₹ 50,000/- in aggregate. Copy of the account book has not been filed along with the grounds of appeal. The names and details of the said parties are not indicated. It is not stated that this contention was raised before the Tribunal and copy of the account book was filed before the tribunal
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