UBER INDIA SYSTEMS PRIVATE LIMITED,MUMBAI vs. JT.CIT (TDS)(OSD)-2(3), MUMBAI

In the result, the appeals of the assessee are allowed

194C of the Act are not applicable in the instant case of the assessee as – a) UISPL is not the person responsible for making payment b) UISPL has not entered into any contract with the Driver-Partners c) no „work‟is carried out by the Driver-Partners for UISPL. 3.7. We find that the ld. AR drew our attention

DCIT (TDS)(OSD)-2(3), MUMBAI vs. UBER INDIA SYSTEMS PVT LTD, MUMBAI

In the result, the appeal by the Revenue is dismissed

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

194C of the Act are not applicable in the instant case of the assessee as – a) UISPL is not the person responsible for making payment b) UISPL has not entered into any contract with the Driver-Partners c) no „work‟is carried out by the Driver-Partners for UISPL. 3.7. We find that the ld. AR drew our attention

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI vs. PRARAMBH SECURITIES PRIVATE LIMITED , GUJARAT

In the result, appeals of the Revenue are dismissed

68,07,157/-\nu/s.40(a)(ia) and in A.Y.2023-24 disallowance made is of\nRs.4,57,28,885/-. Besides this in A.Y.2022-23 and 2023-24,\nthe Revenue has also raised the issue of deletion of addition\non account of trade reversal of Rs.5,02,882/- and\nRs.1,08,118/- in A.Y.2023-24.\n4. The brief facts are that the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI vs. PRARAMBH SECURITIES PRIVATE LIMITED, GUJARAT

In the result, appeals of the Revenue are dismissed

68,07,157/-\nu/s.40(a)(ia) and in A.Y.2023-24 disallowance made is of\nRs.4,57,28,885/-. Besides this in A.Y.2022-23 and 2023-24,\nthe Revenue has also raised the issue of deletion of addition\non account of trade reversal of Rs.5,02,882/- and\nRs.1,08,118/- in A.Y.2023-24.\n4. The brief facts are that the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI vs. PRARAMBH SECURITIES PRIVATE LIMITED, GUJARAT

In the result, appeals of the Revenue are dismissed

68,07,157/-\nu/s.40(a)(ia) and in A.Y.2023-24 disallowance made is of\nRs.4,57,28,885/-. Besides this in A.Y.2022-23 and 2023-24,\nthe Revenue has also raised the issue of deletion of addition\n\non account of trade reversal of Rs.5,02,882/- and\nRs.1,08,118/- in A.Y.2023-24.\n\n4. The brief facts are that the assessee

DCIT (TDS) 3(2), MUMBAI vs. RELIANCE LIFE INSURANCE CO. LTD, MUMBAI

The appeal of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

194C vis a vis 194J we find that the order of FAA is correct and needs to be upheld. Accordingly we dismiss the ground as raised by the revenue. 15. Ground nos.3 and 4 relate to applicability of TDS provisions u/s 194D of the Act on Service Tax element in respect of ‗insurance commission‘. Briefly stated relevant facts in this

DCIT (TDS) 3(2), MUMBAI vs. RELIANCE LIFE NSURANACE CO. LTD, MUMBAI

The appeal of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

194C vis a vis 194J we find that the order of FAA is correct and needs to be upheld. Accordingly we dismiss the ground as raised by the revenue. 15. Ground nos.3 and 4 relate to applicability of TDS provisions u/s 194D of the Act on Service Tax element in respect of ‗insurance commission‘. Briefly stated relevant facts in this

DCIT (TDS) 3(2), MUMBAI vs. RELIANCE LIFE INSURANCE CO. LTD, MUMBAI

The appeal of the revenue is dismissed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

194C vis a vis 194J we find that the order of FAA is correct and needs to be upheld. Accordingly we dismiss the ground as raised by the revenue. 15. Ground nos.3 and 4 relate to applicability of TDS provisions u/s 194D of the Act on Service Tax element in respect of ‗insurance commission‘. Briefly stated relevant facts in this

ITO (TDS) 2(3), MUMBAI vs. MANDKE FOUNDATION, MUMBAI

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 5776/Mum/2014 ("नधा"रण वष" / Assessment Year : 2011-12)

section 194J of the Act. Similarly with respect to payment made by the assessee to M/s Lift Schindler India P Ltd., it was observed by the AO that the said concern provided services of Rs.29,68,915/- to the assessee during the year under consideration , on which the assessee has deducted tax at source @ 2% u/s 194C

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

DCIT CEN CIR 22, MUMBAI vs. M.R. CONSTRUCTION, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

M.R. CONSTRUCTION,.,MUMBAI vs. ASST CIT CEN CIR 22, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

DCIT CEN CIR 22, MUMBAI vs. M.R. CONSTRUCTION, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

ASST CIT CC-22, MUMBAI vs. JAWAHAR PUROHIT, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

M.R. CONSTRUCTION,.,MUMBAI vs. ASST CIT CEN CIR 22, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

194C Contractor 59,067 Section 194H- Brokerage 3,60,000 Expenses/ Commission Section 194J – Professional 3,00,000 Charges Section 194J – Supervision 11,55,500 Charges 4. Adhoc Disallowance for direct 5,46,850/- Expenses @ 20% of Rs. 2,734,243 as discussed above 5. Adhoc Disallwance for indirect 5,71,717 Expenses