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“short deduction of tax”

TDS / TCSSection 201Section 201359 judgments

ACIT22(1), MUMBAI vs. UNIQUE BANGLES, MUMBAI

In the result, the appeal of the Revenue is partly allowed

ITA 7427/MUM/2025[2023-24]Status: DisposedITAT Mumbai16 Mar 2026AY 2023-24

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit-22(1) Unique Bangles, 322, Piramal 232/234, Shah & Chambers, Mumbai – Vs. Nahar Industrial 400 013. Estate, S. J. Mar, Dhanraj Mill Compound, Lower Parel, Mumbai-400019 Pan/Gir No. Aadfu8125A (Applicant) (Respondent) Revenue By Shri Vivek Perampurna, Ld. Dr Assessee By Shri Subhash Chhajed & Shri Sunil Vankawala, Ld. Ars Date Of Hearing 09.03.2026 Date Of Pronouncement 16.03.2026

Section 139(1)Section 143(1)Section 143(3)Section 144BSection 36(1)(va)Section 40Section 68

under section 40(a)(ia), the Assessing Officer observed that the assessee had allegedly failed to deduct tax at source or had made short deduction of tax in respect of certain payments including rent, professional fees and purchases. The Assessing Officer held that the assessee had violated the provisions relating

INCOME TAX OFFICER, NEW DELHI vs. R L STEEL AND ENERGY LIMITED, NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 3109/DEL/2025[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Rl Steel & Energy Ltd, New Delhi 70, Daryaganj, New Delhi (Appellant) (Respondent) Pan: Aaacr5809B Assessee By : Shri Akhilesh Bhargava, Ca Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 07/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: Shri Akhilesh Bhargava, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 14ASection 43(5)

deducted in accordance with rates prescribed under section 194I of the Act. Accordingly, the Learned AO proceeded to disallow the expenses for short deduction of tax at source in the assessment. 9. The Learned CIT(A) noted that the rate of tax under Section 194I ... 1838/Del/2013 dated 5-2-2018 in support of the contentions of the assessee that for short deduction of tax at source, the provisions of Section 40(a)(ia) of the Act could not be invoked. The Learned CIT(A) also took cognizance of the decision of the Hon’ble Calcutta

M/S SUGEE TEN DEVELOPERS LLP,MUMBAI vs. THE INCOME TAX OFFICER, TDS WARD 2(2)(4),MUMBAI, MUMBAI

In the result, appeals of the assessee bearing ITA No

ITA 8287/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Mar 2026AY 2022-23

Bench: Shri. Arun Khodpia

For Appellant: Ms. Vinita ShahFor Respondent: Shri. Sanjeev Bhagat Sr. AR
Section 133ASection 194ISection 201Section 201(1)Section 250

payments made to the landowners. Consequently, the balance amount of TDS along with interest was demanded on account of short deduction of tax. The Ld. AR relied upon the additional evidence filed before the Bench to demonstrate that the landowners (deductees) had already paid tax on the amount received from

M/S SUGEE TEN DEVELOPERS LLP,MUMBAI vs. THE INCOME TAX OFFICER, TDS WARD 2(2)(4),MUMBAI, MUMBAI

In the result, appeals of the assessee bearing ITA No

ITA 8286/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Mar 2026AY 2020-21

Bench: Shri. Arun Khodpia

For Appellant: Ms. Vinita ShahFor Respondent: Shri. Sanjeev Bhagat Sr. AR
Section 133ASection 194ISection 201Section 201(1)Section 250

payments made to the landowners. Consequently, the balance amount of TDS along with interest was demanded on account of short deduction of tax. The Ld. AR relied upon the additional evidence filed before the Bench to demonstrate that the landowners (deductees) had already paid tax on the amount received from

M/S SUGEE TEN DEVELOPERS LLP,MUMBAI vs. THE INCOME TAX OFFICER, TDS WARD 2(2)(4),MUMBAI, MUMBAI

In the result, appeals of the assessee bearing ITA No

ITA 8285/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Mar 2026AY 2019-20

Bench: Shri. Arun Khodpia

For Appellant: Ms. Vinita ShahFor Respondent: Shri. Sanjeev Bhagat Sr. AR
Section 133ASection 194ISection 201Section 201(1)Section 250

payments made to the landowners. Consequently, the balance amount of TDS along with interest was demanded on account of short deduction of tax. The Ld. AR relied upon the additional evidence filed before the Bench to demonstrate that the landowners (deductees) had already paid tax on the amount received from

M/S SUGEE TEN DEVELOPERS LLP,MUMBAI vs. THE INCOME TAX OFFICER, TDS WARD 2(2)(4),MUMBAI, MUMBAI

In the result, appeals of the assessee bearing ITA No

ITA 8284/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Mar 2026AY 2018-19

Bench: Shri. Arun Khodpia

For Appellant: Ms. Vinita ShahFor Respondent: Shri. Sanjeev Bhagat Sr. AR
Section 133ASection 194ISection 201Section 201(1)Section 250

payments made to the landowners. Consequently, the balance amount of TDS along with interest was demanded on account of short deduction of tax. The Ld. AR relied upon the additional evidence filed before the Bench to demonstrate that the landowners (deductees) had already paid tax on the amount received from

DCIT, CIRCLE-73(1), DELHI vs. CANON INDIA PRIVATE LIMITED, DELHI

The appeal of the assessee is allowed

ITA 5588/DEL/2025[2013-14]Status: DisposedITAT Delhi17 Feb 2026AY 2013-14

Bench: BEFORESHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 194Section 201(1)

that payment of CAM charges were essentially a part of the rent, the AO treated the assessee as an assessee-in-default for short deduction of tax at source u/ss. 201(1)/201(1A) of the Act On appeal, it was observed by the Tribunal that the CAM charges paid

DY. COMMISSIONER OF INCOME TAX, DEHRADUN vs. HALLIBURTON OFF SHORE SERVICES INC , MAHARASHTRA

In the result, ground no.3 is allowed

ITA 241/DDN/2025[2021-22]Status: DisposedITAT Dehradun11 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.241/Ddn/2025 िनधा"रणवष"/Assessment Year:2021-22 बनाम Dy. Commissioner Of Income Halliburton Off Shore Services Inc.,Unit No.603, 6Th Floor, Tax, Vs. Aayakar Bhawan, 13-A, Subhash Satellite Gazebo, East Wing,Guru Road, Hargovindji Marg,Andheri Mumbai, Navi Dehradun, Uttarakhand. Mumbai,Maharashtra. Pan No.Aaach5154M अपीलाथ" Appellant ""यथ"/Respondent

Section 19Section 194CSection 194JSection 250Section 40

appellant has further submitted that the AO failed to appreciate that section 40(a)(ia) is not applicable in cases of short deduction of tax(TDS) due to application of a different section but, is applicable only when tax is not deducted at all or not deposited with the Government ... Heavy Industries Company Limited(2025) 176taxmann.com482 wherein it is held that Section 40(a)(ia) of the Act cannot be made applicable to short deduction of tax at source and the disallowance made was directed to be deleted. 5.1.4 I have carefully considered the facts and judicial precedents

DCIT (TDS)-2 3, MUMBAI, MUMBAI vs. NOVARTIS INDIA LIMITED, MUMBAI

In the result, both the appeal of the Revenue and cross-\nobjection of the assessee are allowed for statistical purpose

ITA 5681/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Feb 2026AY 2016-17
Section 194HSection 201

conducted at the premises of the assessee on\n22.10.2019. During the course of survey proceedings, certain\ndefaults relating to non-deduction or short deduction of tax at\nsource on various payments were noticed. Consequent thereto, the\nAssessing Officer passed an order under sections 201(1) and\n201

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S AGILUS DIAGNOSTICS LIMITED, GURGAON

ITA 2836/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldcit, Vs. M/S Agilus Diagnostics Circle-73(1), Room Ltd, No.413, 4Th Floor, Aayakar 306, Tower A, Unitech Bhawa, Laxmi Nagar, Cyber Park, Sector 39, Delhi Gurugram 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacs 2809 J Appellant .. Respondent

For Appellant: Sh. Devashish Jain, Adv &For Respondent: Sh. Rajesh Kumar Dhanesta, Sr
Section 192Section 194JSection 201Section 201(1)Section 246(2)Section 250

case, the Ld. Addl./JCIT (A)-4 Bengaluru has erred in deleting the demand raised u/s 201(1)/201(1A) on account of short deduction of tax at source (TDS) by the Deductor Company on payments made to retained doctors liable for TDS u/s 192. 2. Whether on the facts

URBAN ADMINISTRATION AMD DEVELOPMENT,BHOPAL vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), BHOPAL

In the result, the impugned order is set aside as & by way of

ITA 477/IND/2025[2015-16]Status: DisposedITAT Indore30 Jan 2026AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M Joshidirectorate Of Urban Deputy बनाम/ Administrations & Development, Commissioner Of Vs. Nagar Palika Bhawan, 6 No.Bus Income Tax-Tds, Stop, R.S.Market, Bhopal S.O. Huzur, Bhopal(M.P.) (Tan: Bpldo1618B) (Appellant) (Respondent) Assessee By Shri Sapan Usrethe, Adv. & Ms. Apoorva Garg, Ca Revenue By Shri Anup Singh, Cit Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 30.01.2026 आदेश / O R D E R

Section 201Section 201(1)Section 246ASection 250Section 253

DCIT(TDS), Bhopal dated 28.12.2021, the assessee was found & deemed to be an Assessee in Default for Short deduction of Tax of Rs. 2,98,992/- u/s 201(1) of the Act-for AY 2015-16 & as per provision of section 201(1A), the assessee was held liable

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

ITA 1237/HYD/2025[2022-23]Status: DisposedITAT Hyderabad21 Jan 2026AY 2022-23
For Appellant: \nShri P. Murali Mohan Rao, CAFor Respondent: \nShri K. Vinoth Kannan
Section 154Section 200Section 201Section 201(1)Section 220(2)Section 234ESection 250Section 311

company to the demand that was\nraised by the ITO (TDS), CPC, viz., (i) short payment of tax: Rs.17,005/-; and\n(ii) short deduction of tax: Rs.1,22,275/- (Rs.13,600/- as per order under section\n154, dated 19/04/2022), the CIT(A) observed that as the assessee company\nhad

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(4), HYDERABAD

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

ITA 1236/HYD/2025[2021-22]Status: DisposedITAT Hyderabad21 Jan 2026AY 2021-22

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Shri K. Vinoth Kannan
Section 154Section 200Section 200(3)Section 201Section 201(1)Section 220(2)Section 234ESection 250Section 311

assessee company to the demand that was raised by the ITO (TDS), CPC, viz., (i) short payment of tax: Rs.17,005/-; and (ii) short deduction of tax: Rs.1,22,275/- (Rs.13,600/- as per order under section 154, dated 19/04/2022), the CIT(A) observed that as the assessee company

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (SAHAR BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

ITA 6442/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

operative Bank Ltd.\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10.\nOn the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT CO OPERATIVE BANK LIMITED (FOUR BUNGALOWS BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

ITA 6441/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

treated as\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10. On the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MAHIM BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

Appeal of the assessee is partly allowed for statistical purposes

ITA 6440/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)

treated as assessee in default u/s 201 of the Act. The demand raised by the AO in respect of non-deduction and short deduction of tax at source along with interest thereon is required to be deleted.\n10. On the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT CO-OPERATIVE BANK LTD (MAHIM BRANCH),MUMBAI vs. ITO (TDS)- WARD 1(1)(4), MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

ITA 6439/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

operative Bank Ltd.\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10. On the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MAHIM BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

The appeal of the assessee is partly allowed for statistical\npurposes

ITA 6438/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

operative Bank Ltd.\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10. On the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT C-OPERATIVE BANK LIMITED (MAROL BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

ITA 6437/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

operative Bank Ltd.\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10.\nOn the other hand, the Id. Sr. DR submitted that

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MAROL BRANCH) ,MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

ITA 6436/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

treated as\nassessee in default u/s 201 of the Act. The demand raised by the AO in respect of\nnon-deduction and short deduction of tax at source along with interest thereon\nis required to be deleted.\n10. On the other hand, the Id. Sr. DR submitted that

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