DCIT CC - 3(4), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI
What did the Tribunal hold?
The Tribunal held that the CIT(A) had erred in allowing the assessee's appeal by relying on CBDT Circulars and High Court judgments that were not applicable to the facts of the case. The Tribunal found that the JV was indeed a separate entity and the assessee was liable for TDS.
What were the facts?
The Revenue appealed against the CIT(A)'s order, which had allowed the assessee's appeal regarding the non-deduction of TDS on interest paid to a Joint Venture (JV). The AO held that the JV was a separate entity and the assessee was liable for TDS under Section 194A.
What were the issues?
Whether the assessee was liable to deduct TDS on interest paid to a Joint Venture, and whether the JV was a separate entity for tax purposes.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(4)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Katira Construction Ltd. v. UOI77 citing31 Taxmann.com 250 · 2013 · HC
- CIT v. SMSL-UANRCL11 citing372 ITR 429 · 2015 · HC
- 323 ITR 3226 citing323 ITR 322
- CIT v. Smsl Uanrcl(JV)6 citing378 ITR 429
Income Tax Appellate Tribunal, ‘C’ BENCH
Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL
Heard together (6 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER AMIT SHUKLA (J.M): ITA NOs. 3068/Mum/2024 & 3065/Mum/2024 The aforesaid appeals have been filed by the Revenue against
The order continues below.
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More judgments on Section 194A
- S R P Jutha 13 Rajkot VI and Gr S Ma, Rajkot vs ITO WD 1(2)(1) Rajkot, RajkotITA 951/RJT/2025[2017-18]Status: Disposed9 Oct 2026AY 2017-18
- Welspun Aunta Simaria Project Private… vs DCIT, Circle-78(1), DelhiITA 6559/DEL/2025[2019-20]Status: Disposed6 Oct 2026AY 2019-20
- Lakhmanbhai Maru, Vadodara vs ITO, Ward 1(2)(1), Vadodara, Aayakar…ITA 1046/AHD/2026[2024-25]Status: Disposed30 Sept 2026AY 2024-25
- Hexad Infosoft Private Limited… vs Deputy Commissioner of Income Tax Circle…ITA 1713/BANG/2026[2017-18]Status: Disposed29 Sept 2026AY 2017-18
- Hexad Infosoft Private Limited… vs Deputy Commissioner of Income Tax Circle…ITA 1712/BANG/2026[2016-17]Status: Disposed29 Sept 2026AY 2016-17
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