THE GREAT EASTERN SHIPPING CO. LTD ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, TDS, CIRCLE 2(3), MUMBAI
In the result, all the eight appeals filed by the assessee are allowed
ITA 2778/MUM/2024[2019-20]Status: DisposedITAT Mumbai27 Nov 2024AY 2019-20
Bench: Shri Sandeep Gosain & Ms. Padmavathy S
Section 192(3)Section 201Section 220(2)Section 250
liable to be charged although the facility for adjustment of TDS is permitted within the financial year, by misinterpreting the provisions of Section 192(3) of the Act.
4) The learned Commissioner of Income Tax (Appeals) erred in disregarding the judgements of several High Courts and Tribunals relied upon ... year. In fact, the Appellant discharges the entire TDS liability within the due date as prescribed by the Act.
8) The provisions of Section 192(3) of the Act read as under:
"The person responsible for making the payment referred to in sub-section (1) or sub-section