Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (5) TMI 1502 - AT - Income TaxTDS u/s 194C or 194J - short deduction of tds - Payments to various fields agent for conducting research surveys, data compilation and translation etc. - additions u/s 40(a)(ia) - HELD THAT:- Respectfully following the aforesaid decision(s) of tribunal in assesses own case in preceding years viz. AY 2005-06 to 2011-12 [2018 (7) TMI 1973 - ITAT MUMBAI], [2014 (2) TMI 1355 - ITAT MUMBAI], [2012 (7) TMI 614 - ITAT MUMBAI], [2016 (2) TMI 1147 - ITAT MUMBAI], [2016 (7) TMI 1394 - ITAT MUMBAI] with a view to maintain judicial discipline and also to maintain consistency as outlined by Hon’ble Supreme Court in the case of Radhasoami Satsang v. CIT [1991 (11) TMI 2 - SUPREME COURT] we decide this issue in favour of the assessee by holding that keeping in view factual matrix of the case, no disallowance u/s 40(a)(ia) of the 1961 Act is warranted in the instant case after observing that the assessee has duly deducted income-tax at source u/s. 194C of the 1961 Act on payments made by the assessee to field agents for conducting research surveys, data compilation and translation etc.. Thus, Revenue fails in this appeal.
|