DIGP GC CRPF,NAGPUR vs. DCIT CPC (TDS), GHAZIABAD

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.294 & 295/Nag/2022 Assessment Year : 2015-16 Digp Group Centre Crpf, Vs. Dcit, Cpc (Tds), D/O The Office Of The Digp Ghaziabad. Group Centre, Hingna Road, Digdoh Hills, Midc Area, Nagpur- 440019. Pan : Aaagd0143E Appellant Respondent Assessee By : Shri Kapil Hirani Revenue By : Smt. Rashmi Mathur Date Of Hearing : 17.07.2023 Date Of Pronouncement : 18.07.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 15.12.2021 For The Assessment Year 2015-16 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal In Ita No.294/Nag/2022 For The Assessment Year 2015-16 Are Stated Herein.

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BANK OF INDIA,SIHORA BRANCH vs. ACIT,CPC(TDS), GHAZIABAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Vikram Singh Yadav & Shri Yogesh Kumar U.S

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BANK OF INDIA ,PRASHEONI BRANCH vs. ACIT,CPC,TDS, GHAZIABAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Vikram Singh Yadav & Shri Yogesh Kumar U.S

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

HASANTE BURHANIAH FIDAYYIAH TRUST,NAGPUR vs. INCOME TAX OFFICER (TDS) WARD-1, NAGPUR

In the result, assessee’s appeals for A

Bench: Shri Sandeep Gosain & Shri Arun Khodpia

TDS provisions stringent which is a charging section and Sec. 200A on the other hand is a machinery provision for making prima facie adjustment. The Hon'ble Court in the case of Rajesh Kourani vs Union of India (supra) held that:- 16, We now come to the petitioner's central challenge viz. of non permissibility to levy fee under section

BLOCK DEVELOPMENT OFFICER PANCHAYAT SAMITI MURTIZAPUR ,MURTIZAPUR vs. INCOME TAX OFFICER (TDS) WARD -1(2), AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BLOCK DEVELOPMENT OFFICER , PANCHAYATI SAMITI , MURTIZAPUR ,MURTIZAPUR vs. INCOME TAX OFFICER (TDS) WARD -1, AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

ANIL LADHARAM HASSIJA,GONDIA vs. INCOME TAX OFFICER TDS WARD 2 (4) , BHANDARA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

P.N.DEWALKAR CONSTRUCTION ,NAGPUR vs. ACIT, CPC, TDS, GHAZIABAD

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BLOCK DEVELOPMENT OFFICER ,AKOLA vs. INCOME TAX OFFICER (TDS) WARD 1(2), AKOLA , AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BLOCK DEVELOPMENT OFFICER ,AKOLA vs. INCOME TAX OFFICER (TDS) WARD 1(2) , AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BLOCK DEVELOPMENT OFFICER ,AKOLA vs. INCOME TAX OFFICER (TDS) WARD 1(2) , AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

BLOCK DEVELOPMENT OFFICER PANCHAYAT SAMITI,MURTIZAPUR vs. INCOME TAX OFFICER (TDS) WARD -1(2), AKOLA

Appeals are allowed

Bench: Shri S. S. Godara & Shri G. D. Padmahshali

271H(3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section

SAINATH VIDYALAYA,MAKKEPALLI vs. ITO,TDS WARD-52(3), CHANDRAPUR

In the result, both the appeals of the assessee are\nallowed

271H(3) that too by\nexpressly put bar for penalty under Section 272A by\ninsertion of proviso to Section 272A(2), it can be said\nthat a particular set up for imposition and the\npayment of fee under Section 234E was provided\nbut, it did not provide for making of demand of such\nfee under Section 200A payable under Section