ITO (TDS), PATIALA vs. M/S S.A. SINGH & CO., BHAWANIGARH

In the result, the appeal of the Revenue is dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

TDS @ 2% under Section 194C of the Act. 3.1 Thereafter, the proceedings under section 201(1) of the Act were initiated. During the course of proceedings, information was sought under section 133(6

SH.H.P.SINGH & OTHERS,MOHALI vs. ITO (TDS-2), CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita Nos.236 To 238/Chd/2021 "नधा"रण वष" / Assessment Years :2011-12 & 2012-13 H.P. Singh & Others, बनाम The Ito (Tds-2), 39 West, Chandigarh Maloya, Village Bheloppur, Sector 122, Mohali "थायीलेखासं./Pan No: Aaefh8681G अपीलाथ"/Appellant ""यथ"/Respondent

6 policy formulated by the Govt., cost of which is on the developer of project. In view of this, it implies that it is nothing but constitutes oral agreement, it shall be work / service contract, hence, the provisions of section 194C will be attracted in this case. 6.2 Therefore as such the GMADA being a development authority

SH.H.P.SINGH & OTHERS,MOHALI vs. ITO-WARD-6(4), MOHALI

In the result, the appeal of the assessee is allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita Nos.236 To 238/Chd/2021 "नधा"रण वष" / Assessment Years :2011-12 & 2012-13 H.P. Singh & Others, बनाम The Ito (Tds-2), 39 West, Chandigarh Maloya, Village Bheloppur, Sector 122, Mohali "थायीलेखासं./Pan No: Aaefh8681G अपीलाथ"/Appellant ""यथ"/Respondent

6 policy formulated by the Govt., cost of which is on the developer of project. In view of this, it implies that it is nothing but constitutes oral agreement, it shall be work / service contract, hence, the provisions of section 194C will be attracted in this case. 6.2 Therefore as such the GMADA being a development authority

SH.H.P.SINGH & OTHERS,MOHALI vs. ITO (TDS-2), CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita Nos.236 To 238/Chd/2021 "नधा"रण वष" / Assessment Years :2011-12 & 2012-13 H.P. Singh & Others, बनाम The Ito (Tds-2), 39 West, Chandigarh Maloya, Village Bheloppur, Sector 122, Mohali "थायीलेखासं./Pan No: Aaefh8681G अपीलाथ"/Appellant ""यथ"/Respondent

6 policy formulated by the Govt., cost of which is on the developer of project. In view of this, it implies that it is nothing but constitutes oral agreement, it shall be work / service contract, hence, the provisions of section 194C will be attracted in this case. 6.2 Therefore as such the GMADA being a development authority

M/S SUSHIL KUMAR GUPTA & COMPANY,AMBALA CITY vs. PR.CIT, PANCHKULA

In the result, the appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

TDS u/s 194C for the job charges, which issue was duly considered by the Ld. Assessing Officer during the course of assessment proceedings as is evident from page-9 of the order of Ld. PCIT u/s 263. 4. That the PCIT has failed to appreciate the judgment of jurisdictional Bench of the ITAT, Chandigarh Bench in the case

MUKESH MALHOTRA ,SHIMLA vs. INCOME TAX OFFICER , SHIMLA

In the result, appeal of the assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 194C of Act and during the assessment proceedings the AO issued show cause notice to the assessee and asked as to why TDS as required u/s 194C of the Act was not deducted on the payments to various pay channels. During assessment proceedings the assesseefiled details in respect of the parties to whom subscriptions payment are made after deduction

MUKESH MALHOTRA ,SHIMLA vs. INCOME TAX OFFICER , SHIMLA

In the result, appeal of the assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 194C of Act and during the assessment proceedings the AO issued show cause notice to the assessee and asked as to why TDS as required u/s 194C of the Act was not deducted on the payments to various pay channels. During assessment proceedings the assesseefiled details in respect of the parties to whom subscriptions payment are made after deduction

MUKESH MALHOTRA ,SHIMLA vs. INCOME TAX OFFICER, WARD-1, SHIMLA, SHIMLA

In the result, appeal of the assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 194C of Act and during the assessment proceedings the AO issued show cause notice to the assessee and asked as to why TDS as required u/s 194C of the Act was not deducted on the payments to various pay channels. During assessment proceedings the assesseefiled details in respect of the parties to whom subscriptions payment are made after deduction

MUKESH MALHOTRA ,SHIMLA vs. INCOME TAX OFFICER , SHIMLA

In the result, appeal of the assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 194C of Act and during the assessment proceedings the AO issued show cause notice to the assessee and asked as to why TDS as required u/s 194C of the Act was not deducted on the payments to various pay channels. During assessment proceedings the assesseefiled details in respect of the parties to whom subscriptions payment are made after deduction

MUKESH MALHOTRA,SHIMLA vs. INCOME TAX OFFICER , SHIMLA

In the result, appeal of the assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 194C of Act and during the assessment proceedings the AO issued show cause notice to the assessee and asked as to why TDS as required u/s 194C of the Act was not deducted on the payments to various pay channels. During assessment proceedings the assesseefiled details in respect of the parties to whom subscriptions payment are made after deduction

ITO, WARD 2(1), CHANDIGARH vs. M/S LONGIA ENGINEERS, CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

section 194C and not carrying out requisite enquiries in this regard; that the ld. CIT(A) erred in not appreciating the fact that the Pr. Commissioner of Income Tax had relied upon several judicial precedents in support of her action, which have neither been discussed nor distinguished; that the ld. CIT(A) erred in misconstruing the provisions of the Income

JCIT(OSD)(TDS),CIRCLE, PANCHKULA vs. M/S LIBERTY SHOES LTD.,, KARNAL

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.K. Saini & Shri R.L Negiआयकर अपील सं./Ita No. 268/Chd/2020 "नधा"रणवष" / Assessment Years : 2017-18 Joint Commissioner Of Income M/S Liberty Shoes Ltd., बनाम 13Th Mile Stone, Tax (Osd) (Tds) Circle Aaykar Bhawan, Sector 2 Liberty Puram, G.T. Road, Panchkula Kutail, Karnal Tan No: Rtkl00664G अपीलाथ"/Appellant ""यथ"/Respondent

194C of the Income Tax Act, 1961 instead of 194J. 3. Whether on facts and circumstances of the case the Ld. CIT(A] was correct in holding that the judgment of Hon'ble ITAT in case of Vodafone Idea Ltd. Vs Assistant Commissioner of Income Tax (TDS) Chandigarh [2019] 109 taxmann.com 466(Chandigarh- Tribe.) and Hindustan Coca Cola Beverages

ITO, W-2, BARNALA vs. THE TRUCK OPERATOR UNION, BARNALA

In the result, the appeal of the Revenue is allowed for statistical purposes

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavthe Ito बनाम The Truck Operator Union, Ward-2, Barnala Dhanaula Road, Barnala "थायी लेखा सं./Pan No: Aaaat6497M

194C(2) of the Act where as in the present case, the matter relates to cash payment made in contravention of section 40A(3) of the Act. Thereafter referring to the provision of section 40A(3) as well as the exceptional circumstances provided under Rule 6DD, it was held by the AO that no circumstances have been narrated

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PVT LTD, CHANDIGARH

In the result, the order of the ld CIT(A) is confirmed and the grounds of appeal taken by the Revenue are dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

TDS) while granting certificate of lower deduction of tax, the Assessing Officer in the preceding and succeeding years, as also with the view taken by the Assessing Officer in the case of another assessee undertaking identical work, it cannot be said that any error had crept in the order of the Assessing Officer causing prejudice to the revenue and therefore

PUNJAB SMALL INDUSTRIES AND EXPORT CORPORATION LTD.,CHANDIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), CHANDIGARH, CHANDIGARH

In the result, appeal of the Assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

6 (ii) "fees for technical services" shall have the same meaning as in Explanation 2 to clause (vii) of sub-section (1) of section 9; (iii) "professional services" shall have the same meaning as in clause (a) of the Explanation to section 194J; (iv) "work" shall have the same meaning as in Explanation III to section 194C; (v) "rent" shall

VIKAS MEHTA,NEW ANAJ MANDI, RANIA, SIRSA vs. THE DEPUTY DIRECTOR OF INCOME TAX CPC BANGALURU JOA INCOME TAX OFFICER, WARD-1, SIRSA, HARYANA

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

section 194Q are not applicable on the appellant who it merely a Kacha Arhtiya/Pakka Arhtiya/Commission Basis. 3. That the Ld. The Commissioner of Income Tax, ADDL/JCIT (A)-4, Kolkata has erred in not considering the act that the assessee was mainly acting as commission agent/Kacha Arhtiya and he was earning commission from the parties who has deducted TDS U/s 194Q

ASSISTANT CONTROLLER F&A DIRECTORATE OF INDUSTRIES,SHIMLA vs. INCOME TAX OFFICER (TDS), WARD SHIMLA

Bench: the Ld. CIT(A) came to be dismissed without adjudication on merits, primarily on the ground that there was delay in filing of the appeal and that the assessee failed to respond to the notices issued by the Ld. CIT(A).

TDS) Directorate of Industries Ward Shimla Majithia House, Chotta Shimla Himachal Pradesh-171009 Himachal Pradesh "ायी लेखा सं./PAN NO: PTLA11325G अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Abhinav Bijwaria, Advocate राज" की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr. DR सुनवाई की तारीख/Date

KAMLA RETAIL LTD., NOW KNOWN AS M/S ETHOS LTD.,,CHANDIGARH vs. ADDL. CIT, R-I, CHANDIGARH

In the result, the appeal of the assessee is partly

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavm/S. Kamla Retail Ltd. Additional Cit, Range-1, बनाम Now Known As Ethos Limited, Chadigarh. Sco-88-89, Sector 8-C, Chandigarh. "थायी लेखा सं./Pan No: Aadck2345N

6. Per contra, the Ld. DR relied upon the findings of the lower authorities. 7. We have heard the rival contentions and purused the material available on record. It is no doubt true that it is incumbent upon the assessee to account for the expenses in respective financial year in which they are incurred or the liability towards such expenses

DISTRICT ELECTION OFFICE HAMIRPUR, SUB DIVISIONAL MAGISTRATE OFFICE,HAMIRPUR vs. INCOME TAX OFFICER, (TDS) MANDI, MANDI

In the result, Assessee’s appeal is allowed for Statistical Purposes

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 462/Chd/2025 "नधा"रण वष" / Assessment Year : 2018-19 District Election Office, The Ito (Tds), बनाम Sub Divisional Magistrate Mandi Office, Vs. Hamirpur 171001 "थायी लेखा सं./ Pan No: Ptldi1969Q अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Vishal Mohan, Sr. Advocate With Sh. Abhinav, Advocate (Virtual) राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 06.02.2025 Passed By The Ld. Addl. / Joint Commissioner Of Income Tax (Appeals)-9, Mumbai For A.Y. 2018-19. 2. Grounds Of Appeal Are As Under:

TDS), बनाम Sub Divisional Magistrate Mandi Office, Vs. Hamirpur 171001 "थायी लेखा सं./ PAN NO: PTLDI1969Q अपीलाथ"/Appellant ""यथ"/Respondent ( HYBRID HEARING ) "नधा"रती क" ओर से/Assessee by : Sh. Vishal Mohan, Sr. Advocate with Sh. Abhinav, Advocate (Virtual) राज"व क" ओर से/ Revenue by : Sh. Vivek Vardhan, Addl. CIT, Sr. DR सुनवाई क" तार"ख/Date of Hearing