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2024 (3) TMI 611 - ITAT CHENNAITDS demand and interest u/s 201(1) / (1A) - assessee failed to deduct Tax at source (TDS) on certain foreign payments - AR submitted that these payments include reimbursements of expenses which do not require any TDS and all these payees are covered under DTAA which has independent professional service clause in their DTAA - HELD THAT:- Considering the plea of Ld. AR and keeping in mind the fact that the issues raised by the assessee, in this regard, were not addressed by Ld. CIT(A), we set-aside the impugned order and restore the issue back to the file of Ld. AO qua disallowance against impugned payment - AO is directed to consider this claim of the assessee and revise the TDS demand and interest u/s 201(1) / (1A), if required, after meeting the plea raised by Ld. AR. The assessee is directed to substantiate its case.
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