9911796707
TMI Blog2020 (9) TMI 867X X X X Extracts X X X X X X X X Extracts X X X X ..... facts as well as dispute is stated to be pari-materia the same in all the 3 years. 1.2 We have heard the rival submissions and perused relevant material on record including documents placed in the paper-book. Our adjudication to the subject matter of appeals would be as given in succeeding paragraphs. First, we take up appeal for AY 2006-07. ITA No. 2411/Mum/2019, AY 2006-07 2.1 The grounds raised by assessee are as follows: - The Learned Commissioner of Income Tax Appeals-59 disallowed ground no.4 of Appeals without considering the explanation submitted for determination of correct nature of expense to determine the rate of TDS. The learned Commissioner Appeals treated the explanation and clarifications as additional evidence and has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... yam Film Transfer Services & (v) Sagarika Acoustronics Pvt. Ltd. 2.5 The workings of short-deduction of TDS as worked out by Ld. AO aggregated to Rs. 61,317/- which would attract consequential interest of Rs. 49,317/- u/s 201(1A). Thus, a demand of Rs. 1,10,634/- was raised against the assessee. 3. Before Ld. CIT(A), the assessee submitted party-wise details and pleaded no default. However, Ld.CIT(A) refused to admit the additional evidences filed u/r 46A since the assessee, in the opinion of Ld. CIT(A), failed to demonstrate sufficient cause for admission of the same. Consequently, the demand raised against the assessee was upheld. Aggrieved, the assessee is in further appeal before us. 4. Upon careful consideration of impugned order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her appeal before us with similar grounds of appeal. 5.2 We find that in para-2 of remand report for this Assessment Year, Ld. AO has rendered similar findings that considering the nature of services rendered by various payees, TDS was correctly deducted u/s 194C. Therefore, nothing would survive against the assessee and therefore, we are inclined to delete the demand raised against the assessee. The appeal stands allowed. ITA No. 2412/Mum/2019, AY 2008-09 6.1 Facts are pari-materia the same in this Assessment Year also. An aggregate demand of Rs. 13,19,491/- has been raised against the assessee in similar manner. The Ld. CIT(A), following AY 2006-07, dismissed the grounds raised by the assessee. Aggrieved, the assessee is in further app ..... X X X X Extracts X X X X X X X X Extracts X X X X
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