DCIT, Chennai vs. Ford India Pvt. Ltd., Kancheepuram
In the result, the appeal of the assessee for the assessment year 2012-13 is thus allowed
ITA 840/CHNY/2015[2012-13]Status: DisposedITAT Chennai31 Jan 2017AY 2012-13
Section 195Section 201(1)Section 9(1)(vii)
…dit, whichever is earlier, and not on the basis of accrual method of accounting- as has been so vigorously canvassed in the orders of the authorities below. Holding so, a co- ordinate bench of this Tribunal, in the case of C J International Hotels Ltd Vs ITO [79 ITD 506 (2001)] and speaking through one of us (i.e. the Accountant Member), has observed as follows: We find that the lower authorities have proceeded on the fallacy that taxability in the hands of the foreign company and TDS liability of the I.T.A. Nos. 673, 840, 748 and 749 /Chny/2015 Assessment Years: 2011-12 and 2012-13 Page 26 of 55 tax deductor are…