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2020 (2) TMI 1397 - AT - Income TaxDisallowance u/s.40(a)(ia) - TDS u/s 194C OR 194J - expenses towards channel placement fees - HELD THAT:- When there is a short fall in deduction of TDS there cannot be any disallowance u/s.40(a)(ia) of the Act. Undoubtedly in the case on hand the assessee deducted TDS @2% u/s 194C of the Act on the channel placement fees paid. However, the Assessing Officer was of the view that provisions of section 194J would apply and therefore the TDS would have been deducted @10% as against 2%. Therefore as relying on UBJ BROADCASTING PRIVATE LTD. [2019 (9) TMI 541 - ITAT MUMBAI] and M/S. HINDUSTAN THOMPSON ASSOCIATES PVT. LTD. [2016 (7) TMI 1394 - ITAT MUMBAI] this is a case of short deduction of TDS. We uphold the order of the Ld.CIT(A) and reject the ground raised by the revenue.
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