M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE
In the result, the appeal of the assessee is partly allowed for statistical purposes
ITA 2846/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Aug 2023AY 2013-14
Bench: Shri Chandra Poojari & Smt. Beena Pillai
For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 133(6)Section 143(3)Section 144CSection 144C(5)Section 92C(3)
u/s. 201(1A). In our considerate view, the assessee(deductor) gets exonerated from the applicability of TDS provisions on disallowance of the expenditure in question under section 40(a)(i)/(ia) of the Act. This rational is based on the scheme of Section 40(a)(i)/(ia), which is aimed at ensuring that an expenditure should not be allowed