SAPHIRE LANDCRAFT PRIVATE LIMITED,DELHI vs. ASSESSING OFFICER, NEW DELHI
Income Tax Appellate Tribunal, DELHI BENCH ‘C’, NEW DELHI
Before: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman
Per Satbeer Singh Godara, Judicial Member:
These assessee’s twin appeals in ITA Nos. 3212 &
3213/Del/2025 for Assessment Years 2014-15 & 2019-20, arise against the Addl./JCIT(A),
Prayagraj’s
DIN
&
order
No.
ITBA/APL/M/250/2024-25/1074091615(1)
&
1073551112(1) dated 21.02.2025 & 06.03.2025, in proceedings u/s 201(1A) of the Income Tax Act, 1961 (in short “the Act”), respectively.
Cases called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte.
Suffice to say, the assessee’s sole substantive grievance raised in the instant twin appeals challenges both the learned
ITA Nos. 3212 & 3213/Del/2025
Saphire Landcraft Pvt. Ltd.
2
lower authorities respective findings holding it as the assessee in default for not having deducted TDS on payment of external development charges payments made to M/s Haryana Urban
Development
Authority
(“HUDA”) which stand treated as contractual payments u/s 194C of the Act.
We notice in this precise factual backdrop that hon’ble juri ictional high court’s recent decision in Puri Constructions (P) Ltd. Vs. Addl. CIT (2024) 159 taxmann.com 441 (Del.) has already settled the above sole issue against the assessee and in the department’s favour that such are “EDC” payment indeed attracts TDS deduction. We thus uphold both the learned lower authorities’ respective findings treating as the assessee in default in section 201(1) proceedings in very terms.
These assessee’s twin appeals ITA Nos. 3212 & 3213/Del/2025 are dismissed. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 25/09/2025. (S. Rifaur Rahman) (Satbeer Singh Godara) Accountant Member Judicial Member
Dated: 25/09/2025
*Subodh Kumar, Sr. PS*