M/S SUGEE TEN DEVELOPERS LLP,MUMBAI vs. THE INCOME TAX OFFICER, TDS WARD 2(2)(4),MUMBAI, MUMBAI

ITA 8286/MUM/2025Status: DisposedITAT Mumbai06 March 2026AY 2020-211 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the issue was covered by a previous decision of a Co-ordinate Bench. They admitted additional evidence showing that the deductees had already paid tax and restored the matter to the AO for verification and fresh adjudication.

What were the facts?

The assessee, M/s. Sugee Ten Developers LLP, entered into a development agreement with landowners for construction projects. The assessee deducted TDS at 1% under Section 1941A of the Act, but the AO held it should be 10% under Section 194IC, leading to a demand for short deduction and interest.

What were the issues?

Whether the assessee is liable for short deduction of TDS and interest when the deductees have already paid the tax on the income received.

Which sections of the Income-tax Act were involved?

Section 250,Section 201(1),Section 201(1A),Section 133A(2A),Section 194IA,Section 194IC,Section 201

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “G” BENCH MUMBAI

Before: SHRI. ARUN KHODPIA

For Appellant: Ms. Vinita Shah, Shri. Sanjeev Bhagat Sr. AR
For Respondent: Shri. Sanjeev Bhagat Sr. AR
Hearing: 05.03.2026Pronounced: 06.03.2026

PER BENCH: A bunch of appeal of the assessee was preferred against the order of the Ld. Commissioner of Income Tax, ADDL/JCIT Appeal -1, Lucknow [hereinafter referred to as "CIT(A)"] order passed u/s. 250 of the Income Tax Act, 1961 for Assessment Years 2018-19 to 2020-21 & 2022-23, all the orders passed on dated 13.11.2025. The impugned orders emanated from the order of the Ld.

Income Tax Officer, TDS Ward 2(2)(4), Mumbai [hereinafter referred t

The order continues below.

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