RAJESH JAIN, DURG,DURG vs. DCIT, CIRCLE-1(1), BHILAI, BHILAI

ITA 633/RPR/2026Status: DisposedITAT Raipur09 September 2026AY 2018-196 pages
AI SummaryRemanded

What were the facts?

The assessee claimed transport expenses without deducting TDS, relying on Section 194C(6). However, the assessee failed to report these payments in the quarterly TDS statements as required by Section 194C(7). The Assessing Officer disallowed 30% of these expenses.

What did the Tribunal hold?

The Tribunal held that failure to comply with the reporting requirement under Section 194C(7) is a substantive obligation and not a mere procedural lapse. The belated filing of TDS statements does not cure the default. The matter was remanded to the AO for verification of facts regarding the filing of Form 26Q.

What were the issues?

Whether the disallowance under Section 40(a)(ia) is justified when the assessee failed to comply with the reporting requirements of Section 194C(7) despite fulfilling conditions for exemption under Section 194C(6).

Which sections of the Income-tax Act were involved?

Section 194C,Section 40(a)(ia),Section 194C(6),Section 194C(7)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Ravi Agrawal, CA
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 09.09.2026Pronounced: 09.09.2026

PER PARTHA SARATHI CHAUDHURY, JM

The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 29.07.2026 for the assessment year 2018-19 as per the grounds of appeal on record.

2.

Brief facts in this case are as follows: “The assessee, an individual carrying on business under the proprietary concern Jindutt Enterprises, was engaged as a C&F agent for var

The order continues below.

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