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2021 (3) TMI 77 - AT - Income TaxTDS u/s 194C - Addition u/s 40(a)(ia) - assessee failed to deduct tax at source - payment made for purchase of contract material - HELD THAT:- AO did not make any inquiry into the break-up of expenses and unknown to the assessee, the assessee’s authorized representative did not volunteer further information. Also, though these submissions have been mentioned in the impugned order of Ld. CIT(A); we find that the Ld. CIT(A) has not commented on it. We also find that vide letter dated 14/07/2014 the assessee made application for admission of additional evidence during appellate proceedings before Ld. CIT(A). On perusal of order of Ld. CIT(A), we find that she has not made any recording under Rule 46(2) of Income Tax Rules, 1962. In view of the foregoing, there is lack of clarity about facts. As submissions made before us on assessee’s behalf by the Ld. Counsel for the assessee are factual in nature; and require detailed factual verification. As we do not have the benefit of such detailed factual verification in the orders passed by either the AO or the Ld. CIT(A); we are inclined to remand the matter to AO for detailed verification of facts of the case; under the facts and circumstances of the present appeal before us.
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