“tax deducted at source”

Chapter XVII - Collection & Recovery (TDS)Chapter XVII-BChapter XVII-B / Rule 26B / Rule 37BA(2)2,249 judgments

The decision most relied on for tax deducted at source is GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456), cited in 663 judgments on BharatTax.

Leading authorities on tax deducted at source

GE India Technology Centre Pvt. Ltd. v. CIT

327 ITR 456 · 2010 · Supreme Court

663

citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

Gajanan Constructions v. DCIT

74 Taxmann.com 6 · 2016 · ITAT

465

citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

CIT v. Samsung Electronics Ltd.

345 ITR 494 · 2012 · High Court

461

citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

CIT v. Ansal Land Mark Township (P) Ltd.

377 ITR 635 · 2015 · High Court

369

citing judgments

The second proviso to Section 40(a)(ia), introduced by the Finance Act, 2012, is curative and applies retrospectively from April 1, 2005. Consequently, if the recipient of a payment has filed their return and paid taxes on the amount from which tax was not deducted at source, the payer's expenditure cannot be disallowed under Section 40(a)(ia).

Transmission Corporation of Andhra Pradesh v. CIT

239 ITR 587 · 1999 · Supreme Court

243

citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

PCIT v. Peroorkada Service Co-op. Bank Ltd.

442 ITR 141 · 2022 · High Court

208

citing judgments

Interest income earned by a co-operative society from deposits with other co-operative banks, such as district or state co-operative banks, is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, as it is considered income from other sources.

DIT v. GE Packaged Power Inc.

373 ITR 65 · 2015 · High Court

199

citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

CIT v. Ansal Landmark Township (P.) Ltd.

61 Taxmann.com 45 · 2015 · High Court

177

citing judgments

Disallowance under section 40(a)(ia) cannot be made when the assessee has deducted tax at a lesser rate, as opposed to no deduction. The second proviso to section 40(a)(ia) is applicable retrospectively, mitigating disallowance where tax is deposited by the recipient.

Judgments citing tax deducted at source

M/S. Nike India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 203/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Aug 2022AY 2016-17

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.203/Bang/2021 : Asst.Year 2016-2017 M/S.Nike India Private Limited The Deputy Commissioner Of Ground & First Floor, Olympia Income-Tax, Circle 3(1)(1) V. Bangalore. Building, No.66/1, Begmane Tech Park, C.V.Raman Nagar Bangalore – 560 093. Pan : Aabcn9612K. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Bijoy Kumar Panda, Cit-Dr Date Of Pronouncement : 24.08.2022 Date Of Hearing : 23.08.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 27.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Wholesale Distributor Of Nike Brand Products In India. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 30.11.2016 Declaring Total Loss Of Rs.164,42,63,191. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Served. During The Course Of Assessment Proceedings, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The 2 It(Tp)A No.203/Bang/2021. M/S.Nike India Private Limited. Arm’S Length Price (Alp) Of The International Transaction Undertaken By The Assessee With Its Associate Enterprises (Aes). The Tpo Vide Order Dated 31.10.2019, Passed U/S 92Ca Of The I.T.Act, Proposed The Tp Adjustment Totaling To Rs.63,27,41,494 Under Various Segments. The Details Of The Same Are As Follows:- Segment Adjustment (Rs.) Issue Of Sourcing Commission 30,57,35,722 Reimbursement Of Expenses 17,77,95,683 Third Party Royalty 2,00,08,967 Amp Expenses 12,92,01,122 Total 63,27,41,494

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR

Section 143(2)Section 143(3)Section 92C

Learned AO / Learned TPO / Hon'ble DRP erred in not taking cognizance of the Form 16 submitted by the Appellant detailing the Tax Deducted at Source deducted on such salary payments to expatriates. Further, the Learned AO / Learned TPO / Hon'ble DRP has erred in placing reliance

Orient Overseas Container Line Limited, Mumbai vs. Office of the Deputy Commissioner of Income Tax (International Tax)-3(2)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 826/MUM/2022[2018-19]Status: DisposedITAT Mumbai23 Aug 2022AY 2018-19

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleorient Overseas Container Line Limited V. Dcit(It)-3(2)(2) C/O. Oocl (India) Private Limited 16Th Floor Icc Chambers, 5Th Floor Air India Building Saki Vihar Road, Opp. Santogen Silk Mills Nariman Point Powai, Mumbai - 400072 Mumbai – 400 021 Pan: Aaaco5679E (Appellant) (Respondent) Assessee By : Shri Nikhil Tiwari Department By : Ms. Bharati Singh

For Appellant: Shri Nikhil TiwariFor Respondent: Ms. Bharati Singh

Section 143(2)Section 143(3)Section 144C(5)Section 154Section 234CSection 44B

Overseas Container Line Limited certain mistakes apparent on record. For the sake of clarity, it is reproduced below: - “Short Grant of credit of Tax deducted at source ('TDS') 1.1 For the captioned AY, an amount of Rs. 1,43,26,628 was claimed as TDS by OOCLL in the return ... However, the same is appearing under Part D (Details of Paid Refund) of Form 26AS and not appearing under Part A (Details of Tax Deducted at Source). Details of TDS deducted as appearing on the NSDL Portal is enclosed as Annexure 5 for your goodself's reference. 1.3 Further, with

M/S. Yelahanka - Ap Border Tollways Private Limited, Bengaluru vs. Income Tax Officer, Ward-7(1)(4), Bangalore

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 458/BANG/2022[2016-17]Status: DisposedITAT Bangalore22 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17 M/S. Yelahanka-Ap Border Tollways Pvt. Ltd., # 702, Provident The Income-Tax Welworth City, Officer, Yelahanka- Ward – 7[1][4], Doddaballapur Road, Bengaluru. Vs. Marashandra, Bengaluru – 562 163. Pan: Aaacy7243E Appellant Respondent Assessee By : Shri V. Srinivasan, Advocate : Shri Sankar Ganesh K, Jcit Revenue By Dr Itat Date Of Hearing : 08-08-2022 Date Of Pronouncement : 22-08-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 28/03/2022 Passed By The Ld.Cit(A)-11, Bangalore Relating To Assessment Year 2016-17 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law, Equity, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Case.

For Appellant: Shri V. Srinivasan, Advocate

Section 133Section 142(1)Section 143(2)Section 41Section 68

Rs.87,000 M/s. MDP Partners LLC : Rs.1,60,700 ii) Details of Current Liability: Salary : Rs.9,37,742 Rent Payable : Rs.1,77,850 Tax Deducted at Source : Rs.1,41,12,312 2.5 Against the above show cause notice, detailed reply was furnished through e-Proceedings on 05.12.2019 and further clarification ... mentioned in the notice. The assessee also produced confirmation from M/s Ramalingam Construction Co. (II Ltd. 2.6 The assessee also furnished details of Tax Deducted at Source and remittance details as per the details called for in the notice. The learned assessing officer sought additional details of interest paid

Kantilal Jain, Bangalore vs. Income Tax Officer, Ward-3(3)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 579/BANG/2022[2017-18]Status: DisposedITAT Bangalore18 Aug 2022AY 2017-18

Bench: Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri B.R. Sudheendra, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel

Section 143(1)Section 194DSection 234BSection 234CSection 250

deleted. 3. Grounds relating to short grant of TDS credit 3.1. The learned DCIT, CPC has erred in not granting credit for tax deducted at source at Rs.84,056 as against Rs. 1,21,659 claimed by the appellant in the return of income. 3.2. The learned CIT(A), NFAC ... erred in not adjudicating the specific ground raised by the appellant in relation to the short grant of tax deducted at source. Kantilal Jain, Bangalore Page 3 of 20 3.3. On facts and circumstances of the case and law applicable, the appellant is entitled to claim the entire credit

Dell India Private Ltd., Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92C

section 40(a)(ia) of rebates given to customers (Ground No. 5) 53. During the assessment proceedings, the AO called for details of taxes deducted at source on various payments including an amount of Rs. 20,37,71,038/- was in the nature of rebate given to distributors. The assessee ... computation of income for AY 2010-11. During the course of hearing the AO called on the assessee to furnish the details of tax deducted at source on the amount claimed as deduction. Since the assessee was able to furnish evidences of tax deducted at source to the extent

Australia and New Zealand Banking Group Ltd, Mumbai vs. DCIT(It) 1(1)(2), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 5129/MUM/2017[2013-14]Status: DisposedITAT Mumbai10 Aug 2022AY 2013-14

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Milind Chavan, Sr. DR

Section 133(6)Section 143(3)Section 144C(13)Section 92C

levying surcharge and education cess on the income of the Appellant taxable under the provisions of IA treaty. Ground 6: Non-grant of taxes deducted at source The learned AO has erred in not granting the full credit for tax deducted at source under the provisions of Income-tax

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals by the assessee are allowed

ITA 1512/BANG/2013[2008-09]Status: DisposedITAT Bangalore10 Aug 2022AY 2008-09

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri K V Aravind, Standing Counsel

cause why the distribution fees payable to GIL should not be regarded as ‘royalty’ under the Act and consequently proceeded for withholding of tax deduction at source u/s. 195 of the Act. In response, the assessee provided the requisite details and also made submissions in this regard. However ... deductee is a resident taxpayer, shall be passed within two years from the end of the financial year in which the statement of tax deduction at source is filed by the deductor. Where no such statement is filed, such order can be passed up till four years from

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals by the assessee are allowed

ITA 1511/BANG/2013[2007-08]Status: DisposedITAT Bangalore10 Aug 2022AY 2007-08

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri K V Aravind, Standing Counsel

Kirtida Rameshchandra Chandarana, Mumbai vs. CIT (A) National Faceless Appeal Center, Delhi

In the result appeal of the assessee is fully allowed with consequential relief in terms of reversal of interest charged u/s 234B and 234C with immediate grant of refund if any with consequential i...

ITA 122/MUM/2022[2013-14]Status: DisposedITAT Mumbai05 Aug 2022AY 2013-14

Bench: Shri Aby T Varkey & Shri Gagan Goyalkirtida Rameshchandra Chandarana, Flat No. 74, 7Th Floor, Sangita, Arthur Bunder Road, Colaba, Mumbai-400005. Pan: Aadpc1459Q ...... Appellant Vs. Cit (Appeals), National Faceless Appeal Centre, Delhi. ..... Respondent Appellant By : Sh. Ameet Patel Respondent By : Sh. Vijay Kumar Soni, Sr. Dr Date Of Hearing : 12/05/2022 Date Of Pronouncement : 05/08/2022

For Appellant: Sh. Ameet PatelFor Respondent: Sh. Vijay Kumar Soni, Sr. DR

Section 154Section 194Section 234BSection 244ASection 250

assessee has raised the following grounds of appeal: 2 ITA No. 122/Mum/2022-Kirtida Rameshchandra Chandarana “I. DISALLOWANCE OF CREDIT FOR TAXES DEDUCTED AT SOURCE WHEN IT IS DULY APPEARING IN FORM 26AS AND THE CORRESPONDING INCOME IS ALSO OFFERED TO TAX. 1.1 On the facts and the circumstances of the case ... learned Commissioner of Income Tax (Appeals) (herein referred to as 'CITA) has erred in confirming the withdrawal of credit for taxes deducted at source (TDS) under section 1943 of the Income Tax Act, 1961, amounting to Rs. 413,750 in respect of professional fees earned by the appellant which

Luxury Lifestyle Trading India Pvt. Ltd, Mumbai vs. DCIT CPC.-Cell -TDS, Mumbai

ITA 1991/MUM/2021[2014-15]Status: DisposedITAT Mumbai05 Aug 2022AY 2014-15

For Appellant: Shri Mukesh B. AdvaniFor Respondent: Shri Mehul Jain

Section 1Section 154Section 200ASection 234E

issued under Section 200A of the Act on ITA Nos. 1991 to 1998/Mum/2021 Assessment Years: 2014-15 & 2015-16 processing of Statement of Tax Deducted at Source [„TDS Statement‟ in short] of each quarter of Financial Years 2013-14 relevant to the Assessment Year 2014-15 and Financial Year

Red Rooster Performance (International) Private Limited, Bangalore vs. The Income Tax Officer, Ward-3(1), TDS, Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 536/BANG/2022[2014-15]Status: DisposedITAT Bangalore05 Aug 2022AY 2014-15

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahured Rooster Performance Vs The Income Tax Officer (International) Pvt. Ltd. Ward 3(1), Tds B-10, Ngef Industrial Estate Hmt Building, Bellary Road Whitefield Road Bangalore 560032 Mahadevapura Post Bangalore 560048 Pan – Aaecr1751N (Appellant) (Respondent) Appellant By: Mrs. Sunaina, Ca Respondent By: Shri K.R. Narayana, Addl. Cit Date Of Hearing: 02/08/2022 Date Of Pronouncement: 05/08/2022 O R D E R Per: L.P. Sahu, A.M. This Is An Appeal Filed By The Assessee Against The Din & Order No. Itba/Nfac/S/250/2022-23/1042909630(1) Of The Learned Cit(A), Nfac, Delhi In Appeal Dated 29.04.2022 For Ay 2014-15. 2. The Solitary Substantial Issue Raised By The Assessee Challenges Levying Of Late Fee Under Section 234E Of The Income Tax Act (The Act) For The Delay In Remittance Of Tds. 3. The Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Designing, Modification, Manufacture, Trading Of Prototype

For Appellant: Mrs. Sunaina, CAFor Respondent: Shri K.R. Narayana, Addl. CIT

Section 154Section 154(1)(c)Section 156Section 200ASection 220(1)Section 220(2)Section 234ESection 271H(1)(a)

section 200A of the Act for making adjustment in respect of delay in filing of statement by the assessee with regard to tax deducted at source by levying fees under Section 234E of the Act. The Hon’ble jurisdictional High Court in the case of Sri Fateharaj Singhvi v. Union

M/S. Airbus Group India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(1), Bangalore

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

ITA 2385/BANG/2019[2015-16]Status: DisposedITAT Bangalore05 Aug 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sumeet Khurana, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R

Section 133(6)Section 143(3)Section 144CSection 92D

India-France Double Taxation Avoidance Agreement. (Tax effect: INR 19,517,792) 7. Short grant of credit for advance tax and tax deducted at source (‘TDS’) and non-grant of Minimum Alternate Tax (‘MAT’) 7.1. That the Learned AO erred in allowing lower advance tax credit amounting

Dz Bank India Representative Office, Mumbai vs. DCIT (It) 2(1)(2), Mumbai

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

ITA 1815/MUM/2018[2014-15]Status: DisposedITAT Mumbai04 Aug 2022AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Dz Bank, India Representative Dcit (International Taxation) Office C/O Srbc & Associates Llp, Range-2(1)(2), 14Th Floor, The Ruby, 29, Senapati Vs. 16Th Floor, Room No. 1612, Air Bapat Marg, Dadar (West), India Building, Nariman Point, Mumbai-400028. Mumbai-400021. Pan No. Aabcd 6455 E Appellant Respondent

For Appellant: Mr. P.J. Pardiwala/Jeet Kamdar, ARFor Respondent: Mr. Somendu Kumar Dash, Sr. DR

recalled for the limited purpose of ad djudication of grounds relating to allow credit of judication of grounds relating to allow credit of tax deducted at source (TDS) by the borrowers on gross interest tax deducted at source (TDS) by the borrowers on gross interest tax deducted at source ... erred Hon’ble CIT(A)/Ld. AO on facts and in law has erred in not granting in not granting credit for tax deducted at source (TDS), including credit for which the credit for tax deducted at source (TDS), including credit for which the credit for tax deducted at source

Dz Bank India Representative Office, Mumbai vs. DCIT (It) 2(1)(2), Mumbai

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

ITA 1814/MUM/2018[2010-11]Status: DisposedITAT Mumbai04 Aug 2022AY 2010-11

For Appellant: Mr. P.J. Pardiwala/Jeet Kamdar, ARFor Respondent: Mr. Somendu Kumar Dash, Sr. DR

Dz Bank India Representative Office, Mumbai vs. DCIT (It) 2(1)(2), Mumbai

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

ITA 1813/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Aug 2022AY 2009-10

For Appellant: Mr. P.J. Pardiwala/Jeet Kamdar, ARFor Respondent: Mr. Somendu Kumar Dash, Sr. DR

Dz Bank India Representative Office, Mumbai vs. DCIT (It) 2(1)(2), Mumbai

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

ITA 1812/MUM/2018[2008-09]Status: DisposedITAT Mumbai04 Aug 2022AY 2008-09

For Appellant: Mr. P.J. Pardiwala/Jeet Kamdar, ARFor Respondent: Mr. Somendu Kumar Dash, Sr. DR

Skv Industrial Plant & Waste Treatment Pvt. Ltd., Mumbai vs. ITO Ward -3(3)(3), Mumbai

ITA 7375/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Aug 2022AY 2014-15

For Appellant: Shri Prakash PanditFor Respondent: Shri Hoshang B. Irani

Section 143(2)Section 143(3)Section 234ASection 254Section 43B

Trib.) wherein it has been held that when the tax deductor cannot ascertain the payee who is the beneficiary of a credit of tax deducted at source, the mechanism of Chapter XVII-B cannot be put into service. If on verification it is found that the payee is identifiable

Expat Engineering India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 503/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Aug 2022AY 2017-18

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Rajgopal, CAFor Respondent: Smt. Priyadarshini Baseganni

Section 139Section 139(1)Section 143(3)Section 2(24)(x)Section 36Section 43B

cannot be allowed as deduction. The relevant observations of the Tribunal are as follows:- “21. As far as delay in remittance of tax deducted at source u/s. 201(1A) of the Act is concerned, we find that the Hon'ble Madras High Court has taken a view that interest paid ... Madras High Court & uphold the order of the CIT(A) insofar as it relates to disallowance of interest on delayed remittance of tax deducted at source u/s. 201(1A) of the Act.” SP No.31/Bang/2022 & ITA No.503/Bang/2022 Page 9 of 23 12. Following the above decision of the Tribunal, we hold

M/S. Brandmark Solution Pvt Ltd, Mumbai vs. TDS CPC/AO NFAC, Delhi

ITA 2410/MUM/2021[2015-16]Status: DisposedITAT Mumbai29 Jul 2022AY 2015-16

Bench: Shri Baskaran Br & Shri Kuldip Singh

For Appellant: Ms. Neha Anchaliya, A.RFor Respondent: Shri C.T. Mathews, D.R

Section 200ASection 234E

w.e.f. 01.06.2015, whereby the A.O. was enabled to compute the fee under section 234E of the Act while processing of statement of tax deducted at source, is prospective in nature has came up for adjudication before the Hon’ble High Courts of various States. The first decision was rendered

M/S. Brandmark Solution Pvt Ltd, Mumbai vs. TDS, CPC/AO Nafc, Delhi

ITA 2409/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Jul 2022AY 2014-15

Bench: Shri Baskaran Br & Shri Kuldip Singh

For Appellant: Ms. Neha Anchaliya, A.RFor Respondent: Shri C.T. Mathews, D.R

Section 200ASection 234E