BANK OF INDIA,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX(TDS), NAGPUR
In the result, all the appeals are allowed
ITA 272/NAG/2022[2011-2012]Status: DisposedITAT Nagpur23 Aug 2023AY 2011-2012
Bench: Shri R.S.Syal & Shri Partha Sarathi Chaudhurysl.
For Appellant: Shri Pratik Sadrani &For Respondent: Shri Sanjay Agrawal
Section 194ASection 201(1)Section 250
customers which ought to have been included, it
will be a case of non-filing of the statements and hence governed by
section 201(3)(ii) of the Act. The sequitur of his conclusion is that the
bank should file individual client-wise statement and if there is
something amiss ... statement. Opining so, he held
that the order passed by the AO was within time limit as the case fell
under section 201(3)(ii) of the Act. In our opinion, the ld. CIT(A) has
taken a hyper technical view of the provision, which, in fact,
contemplates only