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75 results for “TDS”+ Section 194C(1)clear

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Key Topics

Section 201(1)79Section 194C69Section 20156Section 4050Section 194J49TDS48Addition to Income41Section 271C34Deduction26Disallowance

M/S.MALAYALAM COMMUNICATION LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal of the assessee is allowed

ITA 403/COCH/2018[2010-11]Status: DisposedITAT Cochin08 Feb 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 194CSection 194JSection 201(1)

1) ACIT vs. M/s. Sahara One Media and Entertainment Ltd. in ITA Nos. 4548-4549&4550/Mum/2012 dated 23/10/2013 (ITAT, Mum.) wherein it was held as under: “Deduction of TDS u/s 194J or u/s 194C - Nature of agreement - AO was of the view that the "dubbing expenses/print processing fees" and "production expenses" were in the nature of 'fees for technical services

M/S AC CARGO MANAGEMENT P.LTD,,COCHIN vs. THE ITO, COCHIN

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

ITA 320/COCH/2013[2007-08]Status: Disposed

Showing 1–20 of 75 · Page 1 of 4

14
Section 19413
Section 19212
ITAT Cochin
23 Mar 2017
AY 2007-08

Bench: Shri Abraham P. George & Shri George George. K.] आयकर अपील सं./I.T.A. No. 320/Coch/2013. िनधा"रण वष" /Assessment Year : 2007-2008. Vs. M/S. Ac Cargo Management The Income Tax Officer, Pvt. Ltd, Ward 1(1) 1St Floor, Chacko Chambers, Kochi Civil Lines Road, Palarivattom, Kochi 682 025. [Pan Aaeca 2206K] (अपीलाथ" अपीलाथ" अपीलाथ"/Appellant) अपीलाथ" (ू"यथ" ू"यथ" ू"यथ"/Respondent) ू"यथ"

For Appellant: Shri. R. Krishnan, C.A
Section 194Section 194CSection 194ISection 40

section 194C of the Act. If revenue felt that Assessing Officer had taken an erroneous view with regard to application of Sec. 194C of the Act, it should have taken recourse to other remedies under the Act, to address such a situation and cannot improve its case now before us. Since assessee was not liable to deduct TDS on payments

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

194C and 194J refer to any sum paid. Thus as TDS is to be deducted on 'any sum paid'; hence it does not make any difference as to whether the slim is paid as a reimbursement or as a pay merit for rendering services for establishing TDS liability. Hence the payments to USTlPL is disallowed by invoking provisions of section

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

194C and 194J refer to any sum paid. Thus as TDS is to be deducted on 'any sum paid'; hence it does not make any difference as to whether the slim is paid as a reimbursement or as a pay merit for rendering services for establishing TDS liability. Hence the payments to USTlPL is disallowed by invoking provisions of section

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

TDS only on a sum of Rs. 1,32,42,920/- and on the balance amount no tax was deducted at source treating it as mere reimbursement of expenditure to MPCMS. The said payee, i.e. MPCMS also raised different bills. The AO was of the opinion that the money paid towards management consultancy charges under composite contract and the contract

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,EDARIKODE vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (TDS) KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 212/COCH/2021[2016-2017]Status: DisposedITAT Cochin29 Jun 2022AY 2016-2017

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,EDARIKODE vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (TDS) KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 209/COCH/2021[2013-2014]Status: DisposedITAT Cochin29 Jun 2022AY 2013-2014

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,EDARIKODE vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (TDS) KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 211/COCH/2021[2015-2016]Status: DisposedITAT Cochin29 Jun 2022AY 2015-2016

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,MALAPPURAM vs. INCOME TAX OFFICER, WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 208/COCH/2021[2012-2013]Status: DisposedITAT Cochin29 Jun 2022AY 2012-2013

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,MALAPURAM vs. INCOME TAX OFFICER, WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 207/COCH/2021[2011-2012]Status: DisposedITAT Cochin29 Jun 2022AY 2011-2012

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

EDARIKODE SERVICE CO-OPERATIVE BANK LTD,EDARIKODE vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (TDS) KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 210/COCH/2021[2014-2015]Status: DisposedITAT Cochin29 Jun 2022AY 2014-2015

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 192Section 194JSection 201Section 201(1)Section 80C

TDS rate should be applied by him as per Section 194C of the Act. ITA Nos. 207 to 212/Coch/2021 12 M/s. Edarikode Service Co-operative Bank Ltd. 12. In the result, the appeals filed by the assessee are allowed for statistical purposes. Dictated and pronounced in the open Court on 29th July, 2022. (George George K.) Accountant Member Cochin, Dated

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 615/COCH/2010[09-Aug]Status: DisposedITAT Cochin25 Sept 2019

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 611/COCH/2010[2004-05]Status: DisposedITAT Cochin25 Sept 2019AY 2004-05

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 609/COCH/2010[2007-08]Status: DisposedITAT Cochin25 Sept 2019AY 2007-08

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 606/COCH/2010[2004-05]Status: DisposedITAT Cochin25 Sept 2019AY 2004-05

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 613/COCH/2010[2006-07]Status: DisposedITAT Cochin25 Sept 2019AY 2006-07

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 608/COCH/2010[2006-07]Status: DisposedITAT Cochin25 Sept 2019AY 2006-07

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 607/COCH/2010[2005-06]Status: DisposedITAT Cochin25 Sept 2019AY 2005-06

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 614/COCH/2010[007-08]Status: DisposedITAT Cochin25 Sept 2019

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee

M/S JEEVAN TELECASTING CORPN LTD,COCHIN vs. ACIT, COCHIN

In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos

ITA 612/COCH/2010[2005-06]Status: DisposedITAT Cochin25 Sept 2019AY 2005-06

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Iype John, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 194JSection 201Section 201(1)Section 271C

194C (TDS @ 2%) as claimed by the assessee. The Kerala High Court held relying on the decision of hon SC in Bharti Cellular as reported in 234 CTR 146 that if there is no human intervention, there could be no fee for technical services. The HC also held that the Tribunal shall examine an expert as produced by the assessee