M/S CANARA BANK,SHIMLA vs. ITO (TDS), SHIMLA

The Ld. CIT(A) has erred in law and facts of the case while confirming all the additions in the TDS amount of the assessee. 2. The Ld. CIT(A) has erred in law and facts of the case while not allowing the excess TDS deposited for the quarter ending 31st March 2014, which was considered to be short deducted during the previous 3 quarters. 3. The Ld. CIT(A) has erred in law and facts of the case while confirming the calculation of interest under section 201(1A) till the date of passing of order instead of year end when such taxes have been paid. 4. The Ld. CIT(A) has erred in law and facts of the case while rejecting implementation of circular No. 3/2010 dt. 03/02/2010.

The Ld. CIT(A) has erred in law and facts of the case while not considering interest paid on Motor Accidents claims which are exempted from TDS under section 194A(3)(9). 6. The Ld. CIT(A) has erred in law and facts of the case while not considering interest paid to Registrar of High Court and other legal authorities (such as judges of Courts, Session Courts and High Courts) taking the plea that a circular No. 8 of 2011 dt. 14/10/2011 was issued to deal with such cases, whereas the circular was quashed by Delhi High Court later on. Further the assessee has also raised additional grounds which are as under: 1. The Ld. CIT(A) has erred in law and facts of the case while not considering that the AO had no power of survey under section 133A. Hence the survey should be considered ultravires and proceedings of survey and the order passed be quashed. 2. The Ld. CIT(A) erred in law and facts of the case while not considering that the sections 201(1A) and 201(1A) are not the sections to pass an order and hence these orders should not be considered binding upon the assessee. 3. The additional grounds of appeal are legal in nature and goes to the root