COMMISSIONER OF INCOME TAX TDS vs. M/S GRAPHISADS P.LTD.

Admit.

After hearing learned counsel for the parties, the following substantial questions of law are framed for determination:- (i) Whether assessee was liable to deduct tax at source under Section 194-C or 194-I of the Act on the payments made for hiring sites owned by somebody else and putting-up hoardings thereon? . (ii) Whether assessee was deemed to be an assessee in default under Section 201(1) of the Act? . (iii) Whether ITAT was correct in law in deleting the interest charged by Assessing Officer under Section 201 (1A) of the Act despite the fact that the assessee had deducted the tax in short? .

Paper books be filed in accordance with the High Court Rules.

List in due course. . . . . VIKRAMAJIT SEN, J . . . . S. MURALIDHAR, J NOVEMBER 10, 2006 nj . . 22