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2016 (5) TMI 1258 - AT - Income TaxTDS u/s 194C - non deduction of TDS on payments made to a contractor/sub–contractor for services rendered - Held that:- The assessee having made the payments on behalf of its clients, there is no liability to deduct tax at source on the assessee. Consequently, no disallowance under section 40(a)(ia) can be made for alleged failure of the assessee to deduct tax at source on the payment made on behalf of the importers / clients. Therefore, finding no infirmity in the order of the learned Commissioner (Appeals), we uphold the same by dismissing the ground raised by the Department. - Decided in favour of assessee.
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