TMI Blog2018 (9) TMI 1757X X X X Extracts X X X X X X X X Extracts X X X X ..... t a notified institution u/s 194A(iii)(f) of the Act. Therefore, the payment of interest to PIPDIC required to be deducted u/s 194A. Since the assessee has not deducted the tax at source and remitted to Government account, the payment of interest attracts disallowance u/s 40(a)(ia) of the Act. The issue is settled by Hon’ble Supreme Court in the case of Palam Gas Service [2017 (5) TMI 242 - SUP ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2-13. 2. Ground Nos. 1 and 5 are general in nature which does not require specific adjudication. 3. Ground No.2 is not pressed by the Ld. AR during the appeal hearing, hence this ground is dismissed as not pressed. 4. Ground No.3 and 4 are related to the disallowance u/s 40(a)(ia) of the act, made by the Assessing Officer (AO) for not deducting the TDS on interest payment to M/s Pondicher ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... without deduction of tax at source. The said entity, PIPDIC is not a statutory corporation u/s 194A(iii)(b) and not a notified institution u/s 194A(iii)(f) of the Act. Therefore, the payment of interest to PIPDIC required to be deducted u/s 194A of the Act. Since the assessee has not deducted the tax at source and remitted to Government account, the payment of interest attracts disallowance u/s 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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