RAMANIYAM REAL ESTATES PVT. LTD.,CHENNAI vs. ACIT, CIRCLE-I, LTU,, CHENNAI

ITA 2439/CHNY/2025Status: DisposedITAT Chennai07 January 2026AY 2018-196 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that the party-wise details submitted by the assessee indicated that payments made to each party were below the threshold limits prescribed for TDS. Consequently, the disallowance under Section 40(a)(ia) was not applicable. The matter was restored to the Assessing Officer for verification of these payments.

What were the facts?

The assessee's appeal concerns the assessment year 2018-19. The Assessing Officer disallowed 30% of expenses totaling Rs. 47,87,748/- under Section 40(a)(ia) for alleged non-deduction of TDS, a disallowance confirmed by the CIT(A). The assessee argued that payments to parties did not exceed the threshold limits for TDS.

What were the issues?

Whether disallowance under Section 40(a)(ia) is sustainable when payments are below TDS threshold limits, and if the lower authorities properly considered the evidence.

Which sections of the Income-tax Act were involved?

Section 40(a)(ia),Section 194C,Section 194I,Section 194J,Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, B BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S. R. RAGHUNATHA

Hearing: 03.12.2025Pronounced: 07.01.2026

PER S. R. RAGHUNATHA, AM : This appeal filed by the assessee is directed against order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [herein after “ld.CIT(A)] dated 13.08.2025 and pertains to Assessment Year(A.Y.) 2018-19 against the order of the National Faceless Assessment Centre, Delhi, passed u/s.143(3) r.w.s 144B of the Income Tax Act, 1961 (in short ‘the Act

The order continues below.

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