ASSTT COMMISSIONER OF INCOME TAX, RANCHI vs. SRI SANJAY KUMAR JAIN, RANCHI

ITA 381/RAN/2025Status: DisposedITAT Ranchi30 June 2026AY 2015-164 pages
AI SummaryDismissed

What were the facts?

The assessee, a transport contractor, made payments to truck owners who provided their PAN details, complying with Section 194C(6). However, the assessee failed to furnish these details to the prescribed authorities as required by Section 194C(7). Consequently, the Assessing Officer disallowed the expenditure under Section 40(a)(ia) for non-deduction of TDS.

What did the Tribunal hold?

The Tribunal held that compliance with Section 194C(6) is independent of Section 194C(7). Following precedent from the ITAT Hyderabad Bench and the Madras High Court, the Tribunal upheld the CIT(A)'s decision to delete the disallowance.

What were the issues?

Whether non-furnishing of details to the prescribed authority under Section 194C(7) vitiates the benefit available under Section 194C(6) and leads to disallowance under Section 40(a)(ia).

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Ajay Poddar, Advocate
For Respondent: Shri Huidrom Robindro Singh, CIT-DR
Hearing: 30.06.2026Pronounced: 30.06.2026

Per Bench: This is an appeal filed by the revenue against the order of the NFAC, Delhi [hereinafter referred to as the ‘CIT(A)’] in appeal no. NFAC/2014-15/10054861 dated 20.06.2025 for the assessment year 2015-16. 2. Shri Ajay Poddar, Advocate represented on behalf of the assessee and Shri Huidrom Robindro Singh, CIT-DR represented on behalf of the revenue.

3.

It was submitted by the ld. CIT-DR that the assessee is a transport contractor and the assessee has made payments to various truck owners who had admittedly given the assessee the necessary details in respect of their PAN numbers and had complied to the provisions of section 194C(6) of the Act. It was the submission that however the asses

The order continues below.

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