PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE - 2(4), HYDERABAD
In the result, the appeal filed by the assessee is allowed
ITA 451/HYD/2024[2017-18]Status: DisposedITAT Hyderabad27 Nov 2024AY 2017-18
Bench: Shri Manjunatha G. Hon’Ble & Shri K. Narasimha Chary, Hon’Bleassessment Year – 2017-18 Prathima Infrastructure Limited, Vs. The Assistant Commissioner Of Income Tax, Filmnagar, Central Circle – 2(4), Hyderabad. Hyderabad. Pan : Aabcp2098P. (Respondent) (Appellant) Assessee By: Shri K.C.Devdas, Ca Revenue By: Shri B. Bala Krishna, Cit-Dr Date Of Hearing: 10.10.2024 Date Of Pronouncement: 27.11.2024
For Appellant: Shri K.C.Devdas, CAFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 80I
TDS was deducted by M/s. HCC
Ltd. (principal contractor) on payments made to the appellant under section 194C of the Act which implies that there is an contract- subcontractor relationship between the appellant and M/s. HCC Ltd.
Therefore, it is clear that the appellant is not even constituent of the JV
M/s. HCC-MEIL-BHEL and no direct agreement