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2014 (12) TMI 635 - HC - Income TaxValidity of questions of law framed by Tribunal - Waiver of interest by creditors – TDS not deducted on the component of interest – Held that:- Assessee no doubt was paying interest to its sister concerns on the loans borrowed by it year after year - However, for the three AYs 1989-90, 1990-91 and 1991-92 it did not deduct any tax on the ground that it did not pay any interest at all - In the relevant assessment years, non-deduction of tax at source was not found fault with - It was only at a subsequent stage that a notice was issued proposing action u/s 201 - it was nearly seven years thereafter that a notice was issued - For an assessee to be required to pay the amount, even if due five or six years preceding the demand, would be a serious problem – questions of law framed by the Tribunal for the adjudication are upheld – Decided against revenue.
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