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)
2) of the Act.
7.6
On the facts and in the circumstances of the case, the learned ACIT and DRP have erred in law by confirming the disallowance of management fees paid by the Appellant to USTR, under section 40(a)(i) of the Act, on the grounds of perceived non- withholding of tax at source under section