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2014 (3) TMI 1154 - AT - Income TaxDisallowance u/s.40a(i) - non-deduction of tax at source on the payment of ‘Royalty’ and ‘Technical Fee’ - CIT-A held that liability of the appellant to deduct TDS on a royalties and fees for technical services would arise in the year in which such payment is actually made by the appellant - HELD THAT:- We find that the order of the CIT(Appeals) is well reasoned and detailed. The assessee has been consistently following this method of deducting and depositing of tax at source for the past several years. Even after the AYs under consideration i.e., AYs. 2003-04, 2004-05 & 2005-06, the assessee has been following the same method of deducting TDS at the time of effecting the payments and depositing the same within the time prescribed u/s.200(1) of the Act and the Revenue has accepted the same. We do not find any infirmity in the impugned orders. The appeals of the Revenue are dismissed being devoid of merit.
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