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TMI Blog2023 (9) TMI 617X X X X Extracts X X X X X X X X Extracts X X X X ..... shkar Khanna, Advs. For the Respondent Through: Mr Kunal Sharma, Sr Standing Counsel with Mr Shubhendu Bhattacharya, Standing Counsel and Ms Zehra Khan, Adv. RAJIV SHAKDHER, J.: (ORAL) CM Appl. 43389/2023 1. Allowed, subject to just exceptions. ITA 475/2023 2. This appeal concerns Assessment Year (AY) 2006-07. Via this appeal, the appellant/assessee has assailed the order dated 19.01.202 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e that the appellant/assessee concedes that the CIT(A)'s order dated 01.12.2015 against which an appeal was preferred before the Tribunal was received by it on 18.01.2016. Admittedly, this order remained in its accountant's knowledge till he left the organization. The said order was brought to the notice of the concerned personnel of the appellant/assessee only in July 2018, which led to the insta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act, 1961 [in short, "Act"], obtaining at the relevant point in time, i.e., only from 16.07.2007. In other words, during the period in issue, i.e., AY 2006-07, the appellant/assessee was not required to deduct TDS. 8. Counsel for the appellant/assessee says that this aspect was appreciated by the CIT(A) in the first round and consequently, after scaling down the disallowance for hiring charges, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o provide documentary evidence which would have established that the equipment and machinery had, in fact, been hired by the appellant/assessee. 13.1 In this behalf, the AO noticed that although summons were issued under Section 133(6) of the Act to the sundry creditors, none of them responded to the same. 13.2 Furthermore, the AO noticed that no confirmation of the address of the persons, who s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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