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2015 (10) TMI 1875 - AT - Income TaxFailure to deduct tax at source - interest payable by the assessee under S.201(1A) - Held that:- We restore these matters to the file of the Assessing Officer for the limited purpose of allowing the assessee an opportunity to support and substantiate its case by producing the relevant documentary evidence to show that the concerned payees have already paid tax on the corresponding payments received from the assessee during all the four years under consideration. On verification of the said documentary evidence, the Assessing Officer shall allow appropriate relief to the assessee in the light of the decision of the Hon'ble Supreme Court in the case of Hindustan Beverages Coca-Cola P. Ltd. (2007 (8) TMI 12 - SUPREME COURT OF INDIA). The Assessing Officer is also directed to recompute the interest payable by the assessee under S.201(1A) as per the decision of the Hon'ble Supreme Court in the case of Hindustan Beverages Coca-Cola P. Ltd. (supra). He shall, of course, afford reasonable opportunity of hearing to assessee, before passing appropriate orders in these matters. - Decided partly in favour of assessee for statistical purposes.
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