TMI Blog2016 (6) TMI 1326X X X X Extracts X X X X X X X X Extracts X X X X ..... d gains of business or profession" i.e. at the close of the year? - Held that:- We not inclined to interfere with the orders of the authorities below. Hon'ble Punjab & Haryana High Court in the case of M/s PMS Diesels (2015 (5) TMI 617 - PUNJAB & HARYANA HIGH COURT) held that” Provisions of Section 40(a) (ia) of the Ac t would cover amount payable at any time during the accounting year” . The iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Shr i Sahi l Chadha For the Respondent : Shr i S.K.Mi t tal , DR ORDER Both the appeals by assessee are directed against different orders of ld. CIT(Appeals) -2 Chandigarh dated 01.06.2015 for assessment year 2011-12 and 2012-13. 2. In assessment year 2011-12, assessee challenged the addition of ₹ 13,78,291/- and ₹ 3,09,872/- on account of non-deduction of TDS on inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made in view of the decision of Special Bench of ITAT Vishakhapatnam in the case of M/s Merilyn Shipping Transport in ITA 477/Vizag/2008 and of Allahabad High Court in the case of M/s Victor Shipping Service Pvt . Ltd. 357 ITR 642. 5. The ld. CIT(Appeals) noted that the issue has been decided by Hon'ble Punjab Haryana High Court vide order dated 29.04.2015 in ITA 716 of 2009 in the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Punjab Haryana High Court in the case of M/s PMS Diesels 374 ITR 562 (supra) held that Provisions of Sec t ion 40(a) (ia) of the Ac t would cover amount payable at any time during the accounting year . The issue is, therefore, covered against the assessee by the decision of jurisdictional High Court. The ld. counsel for the assessee did not contribute anything on this issue and no mater ial h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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