TMI Blog2019 (7) TMI 1096X X X X Extracts X X X X X X X X Extracts X X X X ..... AT HIGH COURT] . The ratio of the decision of this Court referred to above is that a person paying interest or any other sum to a nonresident is not liable to deduct tax if such sum is not chargeable to tax under the Act. Thus, the first question proposed by the Revenue is squarely covered. Addition in respect of estimation of Gross profit - HELD THAT:- Findings recorded by the Tribunal are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9 - MR J. B. PARDIWALA AND MR A. C. RAO, JJ. For The Appellant (s) : MRS MAUNA M BHATT (174) For The Opponent (s) : None ORAL ORDER ( PER : HONOURABLE MR.JUSTICE J. B. PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short, the Act, 1961 ) is at the inst ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T(A) deleting the addition of ₹ 1,49,18,219/made in respect of estimation of Gross profit? 2 The first question proposed by the Revenue has something to do with Section 40(a)(ia) of the Act. The issue is with regard to the deletion of the addition made on account of the disallowance of ₹ 23,14,214/under Section 40(a)(ia) of the Act for nondeduction of the tax of the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see, he did not have anything to say beyond that action taken in the original assessment proceedings was correct as, according to the Assessing Officer, there were discrepancies . These findings of the CIT(A) are not claimed to be perverse or factually incorrect. When the Assessing Officer declines to meet the specific points raised by the assessee in first appellate proceedings, there is obvio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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