TMI Blog2020 (3) TMI 1222X X X X Extracts X X X X X X X X Extracts X X X X ..... journment. The appeal was filed was way back on 03.05.2017 and the Ld.A.R. could not explain the mistake in the order of the Ld.CIT(A). In the instant case, the Ld.AR could not bring any mistake of calculation of tax liability u/s 201 and 201(1A). We are unable to accept the contention of the Ld.AR that there was mistake in the tax calculation. From the order of the Ld.CIT(A), we observe that the Ld.CIT(A) has correctly calculated the TDS liability in respect of 162 cases and the assessee failed to show that there was mistake in the order of the Ld.CIT(A). Therefore, we find no error in the order of the Ld.CIT(A) and the same is upheld. Appeal of the assessee is dismissed. - I.T.A.No.257/Viz/2017 - - - Dated:- 6-3-2020 - Shri V. Durg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he joint names was not aggregated for arriving the liability for deduction of TDS and found that aggregate interest exceeds the threshold limit for deduction of tax at source. Therefore, the AO treated the assessee as assessee in default for non-deduction f tax at source u/s 194A to the extent of interest payment of ₹ 2,32,63095/- and arrived the liability u/s 201 and 201(1A) of the Act as follows : 201(1) 201(1A) Total ₹ 26,35,708/- ₹ 7,90,710/- ₹ 34,26,418/- 4.1 The AO also treated the assessee as assessee in default for non submission of Form 15G and 15H to the extent of ₹ 1,00,042/- u/s 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the interest payments covering joint accounts to the extent of ₹ 72,40,704/-. On this issue, the AO followed Circular No.256, wherein, it was held that TDS required to be deducted with highest depositor, whereas clarification given by CBDT to bank was in the hands of first deposit holder. The Ld.A.R. argued that if the clarification of IBA is taken into consideration, there would be no tax liability for TDS as far as joint holders are concerned. The Ld.AR argued that this issue was not considered correctly by the AO and there was a calculation mistake in the computation of TDS liability in respect of joint holders, therefore, requested to remit the matter back to the file of the AO for computing the correct liability of TDS in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... djournment. The appeal was filed was way back on 03.05.2017 and the Ld.A.R. could not explain the mistake in the order of the Ld.CIT(A). In the instant case, the Ld.AR could not bring any mistake of calculation of tax liability u/s 201 and 201(1A). Therefore, we are unable to accept the contention of the Ld.AR that there was mistake in the tax calculation. From the order of the Ld.CIT(A), we observe that the Ld.CIT(A) has correctly calculated the TDS liability in respect of 162 cases and the assessee failed to show that there was mistake in the order of the Ld.CIT(A). Therefore, we find no error in the order of the Ld.CIT(A) and the same is upheld. 7. In the result, appeal of the assessee is dismissed. Order pronounced in the open ..... X X X X Extracts X X X X X X X X Extracts X X X X
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