TMI Blog2019 (1) TMI 141X X X X Extracts X X X X X X X X Extracts X X X X ..... on 05/6/1991. As per the notification scheme U/s 194A(3)(iii)(f) of the Act if any society is registered under the Societies Registration Act 1860 and financed wholly by the Government then as per the notification No. SO3489 dated 22/10/1970, the deduction of tax at source is not required so far as the interest paid to such society. Since this status of STPI being notified U/s 194A(3)(iii)(f) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n short the Act) for the A.Y. 2009-10. The assessee has raised sole effective ground of appeal, which is as under: 1. Under the facts and circumstances of the case, the ld. CIT(A) has erred in upholding a demand of ₹ 2,83,592/- raised by ACIT(TDS), Jaipur on account of interest U/s 201(1A) of the IT Act, 1961. 2. The assessee craves the right to add, amend, alter or modify any of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IAM) being the institution which is exempt from tax U/s 10(23)(3b) of the Act and accordingly deleted the addition made by the Assessing Officer in respect of the payment to NIAM. However, the ld. CIT(A) has confirmed the assessment/demand raised by the Assessing Officer U/s 201(1) in respect of ₹ 2,83,592/- on the interest payment to STPI. 4. Before us, the ld AR of the assessee has subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s exempt from TDS as per the notification No. SO3489 dated 22/10/1970. Hence, the ld AR has submitted that the payment made to the society is not liable for TDS as per the said notification issued U/s 194A(3)(iii)(f) of the Act. However, since this plea was not raised before the authorities below, therefore, he has pleaded that the issue may be remitted to the Assessing Officer for verification an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... equired so far as the interest paid to such society. Since this status of STPI being notified U/s 194A(3)(iii)(f) of the Act has not been verified by the authorities below, therefore, we set aside this issue to the record of the Assessing Officer for verification and adjudication of this issue whether the STPI is a society falling under the category as notified U/s 194A(3)(iii)(f) of the Act as cl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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