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2020 (2) TMI 251 - AT - Income TaxTDS u/s 194C - payment made by the assessee is under a contract to the contract workers - additions in the remand proceedings - HELD THAT:- Once the CIT(A) was satisfied that the payment in question is not liable for TDS then the issue which was set aside for reconsideration and adjudication stands over and decided in favour of the assessee. Disallowance made by the CIT(A) of 20% of the labour expenses by questioning the correctness of the claim is clearly beyond the scope of set aside proceedings and jurisdiction of the CIT(A) in the set aside proceedings. Accordingly, in view of the facts and circumstances of the case, the disallowance of 20% of the labour charges made by the ld. CIT(A) is unjustified and arbitrary and the same is deleted. - Decided in favour of assessee.
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