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“Section 201(1)”

Section References (mined)Section 201Section 201(1)1,701 judgments

The decision most relied on for Section 201(1) is Kourani v. Union OF India (83 Taxmann.com 137), cited in 1,708 judgments on BharatTax.

Leading authorities on Section 201(1)

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

Fateh Raj Singhvi & Ors. v. UOI
289 CTR 602 · 2016 · High Court
844
citing judgments

A fee under Section 234E cannot be levied or adjusted in an intimation under Section 200A for TDS statements pertaining to periods prior to June 1, 2015, as the enabling amendment to Section 200A(1)(c) came into effect only from that date.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

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.

Hindustan Coca Cola Beverage Pvt. Ltd. v. CIT
293 ITR 226 · 2007 · Supreme Court
576
citing judgments

The deductor cannot be treated as an assessee-in-default under Section 201(1) if the deductee has already paid the tax or offered the impugned receipts in their return of income. However, interest under Section 201(1A) for delayed deposit of tax can still be levied up to the date of filing of the return of income by the deductee.

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.

Dundlod Shikshan Sansthan v. Union of India
63 Taxmann.com 243 · 2015 · High Court
397
citing judgments

The imposition of fees for late filing of TDS/TCS returns prior to the Finance Act, 2015 amendments was not illegal, and the Rajasthan High Court found no justification to interfere with such compensatory fees.

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).

Judgments citing Section 201(1)

The Deuty Conservator of Forest, Rajsamand vs. ITO (TDS), Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 84/JODH/2020[2011-12]Status: DisposedITAT Jodhpur13 Mar 2023AY 2011-12

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

The Deputy Conservator of Forest (South), Udaipur vs. ITO (TDS), Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 76/JODH/2020[2012-13]Status: DisposedITAT Jodhpur13 Mar 2023AY 2012-13

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

The Deputy Conservator of Forest (South), Udaipur vs. ITO (TDS), Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 75/JODH/2020[2011-12]Status: DisposedITAT Jodhpur13 Mar 2023AY 2011-12

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

The Deputy Conservator of Foret, Banswara vs. ITO, TDS, Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 117/JODH/2020[2012-13]Status: DisposedITAT Jodhpur13 Mar 2023AY 2012-13

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

The Deputy Conservator of Forest, Banswara vs. ITO, TDS, Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 116/JODH/2020[2011-12]Status: DisposedITAT Jodhpur13 Mar 2023AY 2011-12

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

The Deputy Conservator of Forest, Dungarpur vs. ITO (TDS), Udaipur

In the result, all the appeals of the assessee are treated as allowed for statistical purpose

ITA 103/JODH/2020[2011-12]Status: DisposedITAT Jodhpur13 Mar 2023AY 2011-12

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 133ASection 194CSection 201(1)

following grounds have been raised by the assessee: “ 1.The ld. CIT(A) has erred in sustaining the order passed by ld. AO under section 201(1)/201(1A)/ The order passed by ld. AO was bad in law and bad on facts. 2. The ld. CIT(A) has erred

Jaiprakash Associates Ltd., Noida vs. DCIT(International Taxation), Noida

In the result, the appeals in ITA Nos

ITA 1259/DEL/2020[2014-15]Status: DisposedITAT Delhi13 Mar 2023AY 2014-15

Bench: Shri N. K. Billaiya & Shri Yogesh Kumar U.S.

For Appellant: Shri Ashwani Kumar GargFor Respondent: Shri Ganga Dhar panda
Section 40

1 ITA Nos. 1257 TO 1259/Del/2020 Jaiprakash Associates Ltd., Noida. IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCH: ‘D’ NEW

Jaiprakash Associates Ltd., Noida vs. DCIT(International Taxation), Noida

In the result, the appeals in ITA Nos

ITA 1258/DEL/2020[2013-14]Status: DisposedITAT Delhi13 Mar 2023AY 2013-14

Bench: Shri N. K. Billaiya & Shri Yogesh Kumar U.S.

For Appellant: Shri Ashwani Kumar GargFor Respondent: Shri Ganga Dhar panda
Section 40

1 ITA Nos. 1257 TO 1259/Del/2020 Jaiprakash Associates Ltd., Noida. IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCH: ‘D’ NEW

Jaiprakash Associates Ltd., Noida vs. DCIT(International Taxation), Noida

In the result, the appeals in ITA Nos

ITA 1257/DEL/2020[2012-13]Status: DisposedITAT Delhi13 Mar 2023AY 2012-13

Bench: Shri N. K. Billaiya & Shri Yogesh Kumar U.S.

For Appellant: Shri Ashwani Kumar GargFor Respondent: Shri Ganga Dhar panda
Section 40

1 ITA Nos. 1257 TO 1259/Del/2020 Jaiprakash Associates Ltd., Noida. IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCH: ‘D’ NEW

M/S Wayanad Dist. Co.Op Bank Ltd., Wayanad vs. ITO(TDS), Kozhikode

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 961/COCH/2022[2019-20]Status: DisposedITAT Cochin28 Feb 2023AY 2019-20

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

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

orders of the CIT(A) arose out of the orders passed by the Assessing Officer (AO) under Section 201(1) & 201(1A) of the Act. The relevant assessment years are 2016-17 to 2019-20. The assessee has also filed stay applications seeking stay of recovery of the outstanding demand ... interest payment. The assessee submitted that tax was deducted at source only on maturity of deposits. The AO therefore passed orders under Sections 201(1) & 201(1A) of the Act making the assessee as an assessee in default for AY 2016-17 to 2019-20 and also levied interest

M/S Wayanad Dist. Co.Op Bank Ltd., Wayanad vs. ITO(TDS), Kozhikode

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 960/COCH/2022[2018-19]Status: DisposedITAT Cochin28 Feb 2023AY 2018-19

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

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

orders of the CIT(A) arose out of the orders passed by the Assessing Officer (AO) under Section 201(1) & 201(1A) of the Act. The relevant assessment years are 2016-17 to 2019-20. The assessee has also filed stay applications seeking stay of recovery of the outstanding demand ... interest payment. The assessee submitted that tax was deducted at source only on maturity of deposits. The AO therefore passed orders under Sections 201(1) & 201(1A) of the Act making the assessee as an assessee in default for AY 2016-17 to 2019-20 and also levied interest

M/S Wayanad Dist. Co.Op Bank Ltd., Wayanad vs. ITO(TDS), Kozhikode

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 959/COCH/2022[2017-18]Status: DisposedITAT Cochin28 Feb 2023AY 2017-18

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

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

orders of the CIT(A) arose out of the orders passed by the Assessing Officer (AO) under Section 201(1) & 201(1A) of the Act. The relevant assessment years are 2016-17 to 2019-20. The assessee has also filed stay applications seeking stay of recovery of the outstanding demand ... interest payment. The assessee submitted that tax was deducted at source only on maturity of deposits. The AO therefore passed orders under Sections 201(1) & 201(1A) of the Act making the assessee as an assessee in default for AY 2016-17 to 2019-20 and also levied interest

M/S Wayanad Dist. Co.Op Bank Ltd., Wayanad vs. ITO(TDS), Kozhikode

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 958/COCH/2022[2016-17]Status: DisposedITAT Cochin28 Feb 2023AY 2016-17

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

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

orders of the CIT(A) arose out of the orders passed by the Assessing Officer (AO) under Section 201(1) & 201(1A) of the Act. The relevant assessment years are 2016-17 to 2019-20. The assessee has also filed stay applications seeking stay of recovery of the outstanding demand ... interest payment. The assessee submitted that tax was deducted at source only on maturity of deposits. The AO therefore passed orders under Sections 201(1) & 201(1A) of the Act making the assessee as an assessee in default for AY 2016-17 to 2019-20 and also levied interest

DCIT, Circle-1(1), Bhubanswar vs. M/S. Grid Corporation of Orissa Limited, Bhubaneswar

In the result, appeal of the revenue stands dismissed

ITA 328/CTK/2019[2012-13]Status: DisposedITAT Cuttack20 Feb 2023AY 2012-13

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2012-13 Dcit, Dcit, Corporate Circle Corporate Circle - Vs. Grid Corporation Of O Grid Corporation Of Orissa 1(1), Bhubaneswar. 1(1), Bhubaneswar. Ltd., Ltd., Janapath, Janapath, Bhubanesw Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P. Venugopal Rao, Ars Ved Jain/P. Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench

For Appellant: S/Shri Ved Jain/P. Venugopal Rao, ARsFor Respondent: Shri M.K.Gautam
Section 201(1)Section 40

despite the fact P a g e 1 | 3 Assessment Year : 2012-13 that the assessee failed to comply with the provisions of section 201(1) of the Income Tax Act, 1961 read with Rule 31CACB of the Income Tax Rules, 1962. 4. Ld CIT DR submitted that the certificate

M/S. Grid Corporation of Orissa Limited, Bhubaneswar vs. ACIT-(TDS), Bhubaneswar

In the result, appeal of the assessee stands allowed

ITA 323/CTK/2019[2009-10]Status: DisposedITAT Cuttack20 Feb 2023AY 2009-10

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2009-2010 2010 Grid Corporation Of Orissa Grid Corporation Of Orissa Vs. Acit (Tds), Acit (Tds), Ltd., Ltd., Gridco Gridco House, House, Bhubaneswar. Bhubaneswar. Janapath, Bhubaneswar. Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 12.7.2019 In Appeal No. In Appeal No.0035/17-18 For The Assessment Year The Assessment Year 2009-2010. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: S/Shri Ved Jain/P.Venugopal RaoFor Respondent: Shri M.K.Gautam
Section 154Section 244ASection 244A(2)

IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH

DCIT, Corporate Circle-1(1), Bhubaneswar vs. M/S. Gridco Limited, Bhubaneswar

In the result, appeal of the revenue stands dismissed

ITA 298/CTK/2016[2010-11]Status: DisposedITAT Cuttack20 Feb 2023AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year :2010-2011 2011 Dcit, Corporate Circle Dcit, Corporate Circle-1(1), Vs. Grid Corporation Of Orissa Grid Corporation Of Orissa Bhubaneswar Bhubaneswar Ltd., Ltd., Gridco Gridco House, House, Janapath, Bhubaneswar Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Revenue Against The Order Of The Ld Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 9.5.2016 In Appeal No. In Appeal No.0493/14-15 For The Assessment Year Assessment Year 2010-2011. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: S/Shri Ved Jain/P.Venugopal RaoFor Respondent: Shri M.K.Gautam
Section 194Section 194JSection 197(1)Section 40

date of furnishing of return of income by the resident payee referred to in the said proviso," corresponding amendment has been made in section 201(1) as under:- 'provided that any person, including the Principal officer of a company, who falls to deduct the whole or any part

Johnson Watch Company Pvt. Ltd., New Delhi vs. ACIT, Circle-75(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1080/DEL/2020[2011-12]Status: DisposedITAT Delhi20 Feb 2023AY 2011-12

Bench: Shri C.M. Garg & Shri Pradip Kumar Kediaassessment Year: 2011-12 Johnson Watch Company Pvt. Ltd., Vs. Acit, L-21, Connaught Place, Circle-75(1), New Delhi. New Delhi. Pan: Aabcj9807G (Appellant) (Respondent) Assessee By : None Revenue By : Shri Anuj Garg, Sr. Dr Date Of Hearing : 16.01.2023 Date Of Pronouncement : 20.02.2023 Order Per C.M. Garg, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.01.2020 Of The Cit(A)-38, Delhi, Relating To Assessment Years 2011-12. 2. The Grounds Of Appeal Raised By The Assessee Read As Under:- “1. That The Order Of The Learned Cit(A) Is Bad In Law & On Facts In Confirming The Order Of Ao In Respect Of Following Demands U/S 201(1) & U/S 201(1A) Of The Income Tax Act, 1961:- Tds Demand Total Dlf Utilities Ambience Facilities Ambience Facilities Ltd. Management Private Services Private Limited Limited

For Appellant: NoneFor Respondent: Shri Anuj Garg, Sr. DR
Section 194Section 194CSection 194ISection 201Section 201(1)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : C : NEW DELHI BEFORE SHRI C.M. GARG, JUDICIAL MEMBER AND SHRI PRADIP

Income Tax Officer (TDS), Kota vs. Zila Parishad, Sawai Madhopur

In the result, appeal of the revenue is dismissed

ITA 16/JPR/2023[2019-20]Status: DisposedITAT Jaipur20 Feb 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.15 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years :2018-19 Income Tax Officer, Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: JDHZ00055G vihykFkhZ@Appellant izR;FkhZ@Respondent vk;djvihy la-@ITA No.16 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2019-20 Income Tax Officer(TDS), Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: J

For Appellant: Sh. Neeraj Jain (C.A.)For Respondent: Sh. Jadish (JCIT) fu/kZkfjrh dh vksjls@
Section 194ASection 201Section 201(1)

dated 23.11.2022, which ITO vs. Zila Parishad in turn arises from the order passed by the Income Tax Officer(TDS), Kota passed under Section 201(1)/201(1A)r.w.s 194C & 194A of the Income tax Act, 1961 (in short 'the Act') both dated 15.07.2019. 2. Since the issues involved ... paid the taxes. As such, the appellant though failed to deduct tax at source on the payments u/s.194A, but as per provisions of Section 201(1), the appellant shall not be deemed to be an assessee in default in respect of such tax if such payee (i) has furnished

Income Tax Officer, Kota vs. Zila Parishad, Sawai Madhopur

In the result, appeal of the revenue is dismissed

ITA 15/JPR/2023[2018-19]Status: DisposedITAT Jaipur20 Feb 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.15 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years :2018-19 Income Tax Officer, Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: JDHZ00055G vihykFkhZ@Appellant izR;FkhZ@Respondent vk;djvihy la-@ITA No.16 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2019-20 Income Tax Officer(TDS), Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: J

For Appellant: Sh. Neeraj Jain (C.A.)For Respondent: Sh. Jadish (JCIT) fu/kZkfjrh dh vksjls@
Section 194ASection 201Section 201(1)

dated 23.11.2022, which ITO vs. Zila Parishad in turn arises from the order passed by the Income Tax Officer(TDS), Kota passed under Section 201(1)/201(1A)r.w.s 194C & 194A of the Income tax Act, 1961 (in short 'the Act') both dated 15.07.2019. 2. Since the issues involved ... paid the taxes. As such, the appellant though failed to deduct tax at source on the payments u/s.194A, but as per provisions of Section 201(1), the appellant shall not be deemed to be an assessee in default in respect of such tax if such payee (i) has furnished

Canon India Pvt. Ltd., New Delhi vs. ACIT, Circle-73(1), New Delhi

The appeal of the assessee is allowed

ITA 504/DEL/2020[2011-12]Status: DisposedITAT Delhi15 Feb 2023AY 2011-12

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2011-12 Canon India Pvt. Ltd. Unit Acit No.214 To 218, 2Nd Floor, Vs Circle – 73 (1) Narain Manzil, Barakhamba New Delhi Road, Connaught Place, New Delhi-110001 Pan No.Aaacc4175D (Appellant) (Respondent)

Section 194Section 194CSection 194I

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SH. N. K. BILLAIYA, ACCOUNTANT MEMBER AND SH