TMI Blog2021 (5) TMI 423X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee has not furnished any material to controvert the aforesaid finding of the Assessing Officer for not making compliance with the provision of section 40(a)(ia). In addition to above, it is also noticed that counsel of the assessee has voluntarily agreed for the disallowance of interest expenditure since the assessee has failed to make compliance with the provision of section 40(a)(ia) of the Act. Keeping in view of the aforesaid undisputed facts and circumstances, we do not find any infirmity in the decision of ld. CIT(A). - Decided against assessee. - ITA No. 912/Ahd/2018 - - - Dated:- 9-4-2021 - Shri Rajpal Yadav, Vice President And Shri Amarjit Singh, Accountant Member For the Assessee : Shri M.J. Shah, A.R. For the R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the fact and reason for disallowance stated by the Assessing Officer. 5. Heard both the sides and perused the material on record. It is undisputed fact that assessee has paid employees contribution to PF and towards ESIC beyond the period prescribed in the specified act. Therefore following the decision of Hon ble Gujarat High Court of Gujarat in the case of Gujarat State Road Transport Corporation 366 ITR 170 (Guj), we do not find any infirmity in the decision of ld. CIT(A). Therefore, this ground of appeal of the assessee is dismissed. Ground Nos. 2 to 4 (Disallowance of interest expenses of ₹ 4,21,348/- u/s 40(a)(ia) of the Act) 6. During the course of assessment on examination of the detail filed by the assessee, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otaling to ₹ 4,21,348/- liable for deduction of tax u/s. 194A of the Act. The Assessing Officer has made disallowance of aforesaid interest expenditure as per provision of section 40(a)(ia) of the Act on the ground that assessee has failed to deduct tax u/s. 194 of the Act. The assessee has not furnished any material to controvert the aforesaid finding of the Assessing Officer for not making compliance with the provision of section 40(a)(ia) of the Act. In addition to above, it is also noticed that counsel of the assessee has voluntarily agreed for the disallowance of interest expenditure since the assessee has failed to make compliance with the provision of section 40(a)(ia) of the Act. Keeping in view of the aforesaid undisputed fac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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