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2023 (11) TMI 856 - ITAT CHENNAITDS u/s 194I - Assessee in Default u/s 201(1) / 201(1A) - non deduction of TDS on rental payments - HELD THAT:- As assessee has furnished the complete details of rental payment i.e., Godown Location, address of the Godown, name & PAN of landlord and payment made to each of them. We find that the payment to each of these parties is less than threshold limit of Rs. 1.80 Lacs and therefore, the assessee was not liable for TDS on these payments considering the provisions of Sec.194I. Keeping in mind the nature of assessee’s business, the assessee may be temporality hiring the godown and may not be successful in furnishing adequate documentary evidences to the satisfaction of lower authorities. For that lapse, the assessee has already suffered disallowance u/s 40(a)(ia). But, nevertheless, the details as furnished before lower authorities are sufficient to make a reasonable conclusion that the assessee was not liable for TDS on these payments. Accordingly, the assessee could not be treated as assessee-in-default u/s 201(1) / 201(1A) of the Act particularly when all the payees are having PAN. Decided in favour of assessee.
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