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2022 (4) TMI 798 - AT - Income TaxTDS u/s 195 - Assessee-in-default - demand u/s 201(1) / 201(1A) - assessee paid international ocean freight charges for import of coal to various shipping agencies including M/s Noble Chartering Inc., a British Virgin Islands incorporate entity - HELD THAT:- The undisputed position that emerges is that impugned payments have not been made by the assessee during AY 2010-11 and these payments have been made in subsequent years. This being so, the impugned demand as raised against the assessee in this year would have no legs to stand. Therefore, considering the aforesaid position, we delete the impugned demand as raised against the assessee. - Decided in favour of assessee.
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