RUDRA BUILDWELL PROJECT P.LTD,DELHI vs. DCIT, CENTRAL CIRCLE, , NOIDA

ITA 3216/DEL/2018Status: DisposedITAT Delhi15 January 2025AY 2011-12Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)6 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the lower authorities erred in treating the manpower supply agreement as attracting TDS deduction for technical services. The assessee's appeal was allowed.

What were the facts?

The assessee treated payments made to M/s. Best Infosystems Ltd. as work contracts and deducted TDS under Section 194C. The Revenue contended that these payments were for technical services and attracted TDS under Section 194J.

What were the issues?

Whether the payments made for manpower supply constituted fees for technical services attracting TDS under Section 194J, or were they for work contracts under Section 194C?

Which sections of the Income-tax Act were involved?

Section 194C,Section 194J,Section 201(1),Section 201(1A)

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Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, DELHI BENCH: ‘C’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI S. RIFAUR RAHMAN

Hearing: 25.09.2025Pronounced: 25.09.2025

PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2014-15, arises against the Commissioner of Income Tax (Appeals)/Addl./JCIT(A)- 1, Mumbai’s DIN and order no. ITBA/APL/S/250/2024- 25/1074646000(1), dated 18.03.2025 involving proceedings under section 201 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

2.

Coming to the assessee’s sole substantive ground that both the learned lower authorities herein have erred in law and on facts in treating it as the assessee in default in section 201(1) proceedings we note at the outset that the lower appellate discussion to this effect reads as under: “Submi

The order continues below.

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