In the result, the above captioned appeals filed by the Revenue as well as the
Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani
reassessment order. The only objection of the AO for making the impugned disallowance was non compliance of section 194C(7) of the Act. The appellant has submitted that section 194C(7) of the Act prescribes merely a procedural requirement requiring mechanical compliance, non compliance of which cannot trigger disallowance u/s 40(a)(ia) of the Act. The disallowance