TMI Blog2024 (3) TMI 545X X X X Extracts X X X X X X X X Extracts X X X X ..... the corresponding TDS, involving varying sums, in all these assessment years - HELD THAT:- TDS recoveries pertain to assessee s payments of licence-fee of various CT and X-ray machines which have been treated as rental in nature attracting sec. 194I - AO had duly passed his sec. 201(1) r.w.s. 201(1A) order(s) on 28.01.2016 not holding the assessee as the assessee-in-default in the lead assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as the assessee-in-default in sec. 201 r.w.s. 201(1A), by way of sec. 154 rectification in question. The same is held as not sustainable in law in all these assessment years since involving identical facts. - Shri Satbeer Singh Godara, Judicial Member And Shri Amarjit Singh, , Accountant Member For the Assessee : Shri Veeranna Murgod For the Revenue : Shri Shridhar Dora, Sr.DR ORDER PER BENCH : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... same. We find no reason in Revenue s instant technical objections in light of the assessee s solemn pleadings in it s identical condonation petitions filed along with the relevant medical records of the concerned authorised persons. The impugned identical delay of 547 days stands condoned in light of Collector, Land Acquisition vs. MST Katiji [1987] 167 ITR 471 (SC) that all such technical aspects ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... op that the Assessing Officer had duly passed his sec. 201(1) r.w.s. 201(1A) order(s) on 28.01.2016 not holding the assessee as the assessee-in-default in the lead assessment year 2009- 2010. This followed former round of sec. 154 rectification which stood concluded in assessee s favour on 28.03.2018. the Assessing Officer thereafter took-up yet another sec. 154 rectification in the impugned secon ..... X X X X Extracts X X X X X X X X Extracts X X X X
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