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33 results for “TDS”+ Section 143(1)clear

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Key Topics

Section 143(3)37Section 4035Addition to Income27TDS24Disallowance23Section 194C19Deduction19Section 201(1)18Section 14A16Section 80I

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, MARGAO., MARGAO vs. M/S SALGAONCAR MINING INDUSTRIES PVT. LTD., PANAJI

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

ITA 135/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

143(3) of the Income Tax Act, 1961 (‘the Act’) at a total income of Rs.201,87,55,957/-. While doing so, the Assessing Officer made addition of Rs.24,52,468/- u/s 14A, addition on account of unpaid deposits to sundry creditors of Rs.59,03,90,714/-, disallowance of Rs.2,82,83,020/- debited to the Profit & Loss Account

SALGAOCAR MINING INDUSTRIES PRIVATE LIMITED.,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE., MARGAO

Showing 1–20 of 33 · Page 1 of 2

16
Section 143(1)10
Section 2508

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

ITA 118/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

143(3) of the Income Tax Act, 1961 (‘the Act’) at a total income of Rs.201,87,55,957/-. While doing so, the Assessing Officer made addition of Rs.24,52,468/- u/s 14A, addition on account of unpaid deposits to sundry creditors of Rs.59,03,90,714/-, disallowance of Rs.2,82,83,020/- debited to the Profit & Loss Account

SHRI NITIN A SHIRGURKAR,BELGAVI vs. PR. CIT, HUBBALI

In the result, the appeal of the assessee is allowe

ITA 77/PAN/2020[2015-16]Status: DisposedITAT Panaji13 May 2022AY 2015-16

Bench: Dr. M. L. Meena & Shri Anikesh Banerjee

Section 143(3)Section 14ASection 194A(3)(iii)Section 194A(3)(iv)Section 263Section 40

section 194A(3)(iv) no disallowance is warranted. warranted. 10. The Pr.CIT erred in setting aside the issue of TDS on T erred in setting aside the issue of TDS on subcontract payments subcontract payments evidenced by Tax Audit Report and verified evidenced by Tax Audit Report and verified by A.O in assessment proceedings. by A.O in assessment proceedings

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

143(3) of the I.T. Act, 1961. Further, the investment made in shares of Sesa Goa Ltd., as is evident from the audited books of account is out of surplus money only and no borrowed funds were utilized. The assessee-company purchased 3,38,03,812 equity shares of M/s. Sesa Goa Ltd., in the F.Y. 2008-09 and these

SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 105/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

143(3) of the I.T. Act, 1961. Further, the investment made in shares of Sesa Goa Ltd., as is evident from the audited books of account is out of surplus money only and no borrowed funds were utilized. The assessee-company purchased 3,38,03,812 equity shares of M/s. Sesa Goa Ltd., in the F.Y. 2008-09 and these

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

ITA 390/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Apr 2022AY 2012-13

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

For Appellant: Ms Hiral SejpalFor Respondent: Shri Sourabh Nayak
Section 10(35)Section 115JSection 143(3)Section 14ASection 14A(1)Section 250

143(3) of the Act, for the assessment year [for short “AY”] 2012-2013. ITAT-Panaji Page 1 of 23 M/s Chowgule and Company (Salt) Pvt Ltd ITA No.: 390/PAN/2017, AY : 2012-2013, AABCC5595J 2. The present litigation seeks adjudication on threefold issues, as to whether disallowance u/s 14A can triggered in the absence of exempt income, secondly whether diesel

MADALBAL GOA EXPORTS PVT. LTD,MIRAMAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

In the result, the appeal of the assessee is allowed

ITA 363/PAN/2018[2007-08]Status: DisposedITAT Panaji27 Jun 2022AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Sandip Bhandare, CAFor Respondent: Smt. Rijula Uniyal, Sr. DR
Section 143(3)Section 195Section 250(6)Section 40

143(3) r.w.s. 147 of the Act, date of order 26/02/2013. 2. Brief facts of the case are that assessee paid commission on sales to the foreign party, Wing Shing International Trading Co Ltd, Hong Kong amount to Rs.9,82,962/–, for which the foreign party had fully done the work abroad and it had no permanent establishment in India

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 180/PAN/2025[2022-23]Status: DisposedITAT Panaji18 Nov 2025AY 2022-23

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

143(1) of the Act. 3.2 On Potdar Group of cases a search & seizure action u/s 132 of the Act on 08/11/2021 was carried out and alongside a survey action u/s 133A of the Act on connected group cases was also carried on 09/11/2021. Pursuant to former action and incriminating material found & seized therein and statement recorded during therefore

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 179/PAN/2025[2021-22]Status: DisposedITAT Panaji18 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

143(1) of the Act. 3.2 On Potdar Group of cases a search & seizure action u/s 132 of the Act on 08/11/2021 was carried out and alongside a survey action u/s 133A of the Act on connected group cases was also carried on 09/11/2021. Pursuant to former action and incriminating material found & seized therein and statement recorded during therefore

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 177/PAN/2025[2020-21]Status: DisposedITAT Panaji18 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

143(1) of the Act. 3.2 On Potdar Group of cases a search & seizure action u/s 132 of the Act on 08/11/2021 was carried out and alongside a survey action u/s 133A of the Act on connected group cases was also carried on 09/11/2021. Pursuant to former action and incriminating material found & seized therein and statement recorded during therefore

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 176/PAN/2025[2019-20]Status: DisposedITAT Panaji18 Nov 2025AY 2019-20

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

143(1) of the Act. 3.2 On Potdar Group of cases a search & seizure action u/s 132 of the Act on 08/11/2021 was carried out and alongside a survey action u/s 133A of the Act on connected group cases was also carried on 09/11/2021. Pursuant to former action and incriminating material found & seized therein and statement recorded during therefore

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 175/PAN/2025[2018-19]Status: DisposedITAT Panaji18 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

143(1) of the Act. 3.2 On Potdar Group of cases a search & seizure action u/s 132 of the Act on 08/11/2021 was carried out and alongside a survey action u/s 133A of the Act on connected group cases was also carried on 09/11/2021. Pursuant to former action and incriminating material found & seized therein and statement recorded during therefore

DEMELLO TELEPOWER PRIVATE LIMITED,GOA vs. DEPUTY DIRECTOR OF INCOME TAX, CENTRALIZED PROCESSING CENTRE, INCOME TAX DEPARTMENT, GOA

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 211/PAN/2024[2023-24]Status: DisposedITAT Panaji01 Apr 2025AY 2023-24

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.211/Pan/2024 (A.Y.2023-24 ) Demello Telepower Pvt Ltd, Vs Acit-Circle 1(1), H.No.240,Cotulvaddo, Aaykar Bhavan, . Saligao-403511, Edc Complex, Goa Patto Plaza, Panjim-403001, Goa. Pan .No.Aadcd6928L (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 143(1)Section 199

section 143(1) of the Act restricting the TDS credit to the extent of Rs.85,57,839/- under section 199 of the Act r.w.r

PARKKOT MARITIMA AGENCIES PRIVATE LIMITED,VASCO vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

The appeal of the assessee is partly allowed for statistical purposes in aforestated terms

ITA 169/PAN/2023[2008-09]Status: DisposedITAT Panaji04 Feb 2025AY 2008-09

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 169/Pan/2023 Assessment Year : 2008-09 Parkkot Maritime Agencies Pvt Ltd. Parkkot House, Swatantra Path, Vasco-Da-Gama, Goa-403802 Pan : Aadcp1208P . . . . . . . Applicant V/S Dy. Commissioner Of Income Tax Circle-1, Margoa, Goa. . . . . . . . Respondent Appearances Assessee By : Mr S V Shivrama Iyer [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 28/01/2025 Date Of Pronouncement : 28/01/2025 Order Per G. D. Padmahshali, Am; The Assessee Is In Appeal Against Din & Order No. Itba/Nfac/S/250/2023-24/1055088420(1) Dt. 11/08/2023 Passed U/S 250 Of The Income-Tax Act, 1961 [In Short ‘The Act’] By The National Faceless Appeal Centre, Delhi [In Short ‘Ld. Cit(A)/Nfac’] Which In Turn Arisen Out Of Order Of Regular Assessment Dt. 16/03/2015 Framed U/S 143(3) R.W.S 147 Of The Act By The Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa [In Short ‘Ld. Ao’].

For Appellant: Mr S V Shivrama Iyer [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 143(1)Section 143(3)Section 148Section 199Section 234BSection 250

section 199 is entitled to claim credit of all such TDS deducted by a payer of income in accordance with the provisions of chapter XVII of the Act and paid to the credit of central ex-chequer by a deductor/payer. This credit of TDS is however made available to an assessee only upon filing of periodic TDS statement

M/S DEMPO RESORTS PRIVATE LIMITED,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2, MARGAO

In the result, the appeal of the assessee is allowed

ITA 122/PAN/2018[2012-13]Status: DisposedITAT Panaji15 Jun 2022AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2012-13 M/S. Dempo Resorts Acit, Circle-2, Margao Private Limited Empressa Dempo, Mala Vs. Fontainhas, Panaji, Goa – 403 001. Pan: Aaccd 2126 R (Appellant) (Respondent) Present For: Appellant By : Shri Rajesh Naik, Accountant Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 13.06.2022 Date Of Pronouncement : 15.06.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A) – 2, Panaji In Ita No. 390/Cit(A)/Pnj-1/2014-15 Re-Numbered As Ita No. 342/Cit(A)-2/Pnj/2017-18 Dated 23.01.2018 Against The Order Passed By Acit, Circle-1(1), Panaji U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 29.12.2014. 2. The Grounds Taken By The Assessee In The Present Appeal Are Reproduced As Under:

For Appellant: Shri Rajesh Naik, AccountantFor Respondent: Shri Mayur Kamble, Sr. DR
Section 143(3)Section 40

143(3) of the Income-tax Act, 1961 (hereinafter referred to as the ‘Act’) dated 29.12.2014. 2. The grounds taken by the assessee in the present appeal are reproduced as under: “1. The Learned Commissioner of Income Tax (Appeals) has erred on fact and in law in upholding the order of the Learned Assessing Officer adding income

SMT VANDANA SAMEER MAJALI,BELGAVI vs. INCOME TAX OFFICER, WARD - 2(1), BELGAVI

In the result, the appeal filed by the assesse is allowed for statistical purposes

ITA 14/PAN/2022[2011-12]Status: DisposedITAT Panaji30 Jun 2025AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.14/Pan/2022 (A.Y. 2011-12 ) Smt Vandana Sameer Majali, Vs Ito-Ward-1(2), H.No.189/B1/A, Civil Hospital Road, . Shukrawar Peth, Belagavi-590001. Tilakwadi, Karnataka. Belagavi-590006, . Karnataka. . Pan .No. Apupm1202K (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 143(1)

section 143(1) of the Act. The Assessing Officer (AO) based on the information and after recording of reasons has reason to believe that the income has escaped assessment and has issued the notice u/sec148 of the Act on 27.03.2018 and in compliance the assesse has filed the return of income on 19.08.2018. Further notice u/sec 143(2) and u/sec

SRITHIK ISPAT PRIVATE LIMITED,GOA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) PANAJI,GOA, PANAJI,GOA

The appeal is allowed for statistical purposes

ITA 48/PAN/2025[2016-17]Status: DisposedITAT Panaji31 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year: 2016-17 Srithik Ispat Pvt. Ltd. Plot No. 3, Sanguem Industrial Estate, Sanguem, Goa-403704 Pan : Aaics1765P . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa . . . . . . . Respondent Appearances Assessee By: Mrs Girija Agrawal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing: 30/07/2025 Date Of Pronouncement : 31/07/2025 Order Per G. D. Padmahshali; This Assessee’S Appeal Is Filed U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Challenges Din & Order No 1068425181(1) Dt. 06/09/2024 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’] U/S 250 Of The Act Which Originated From Order Of Assessment Passed U/S 144 Of The Act By Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. [‘Ld. Ao’].

For Appellant: Mrs Girija Agrawal [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]
Section 143(2)Section 144Section 250Section 251Section 251(1)(a)Section 253(1)Section 40Section 68

143(2) of the Act. ITAT-Panaji Page 2 of 8 Srithik Ispat Pvt. Ltd. Vs ACIT ITA No. 048/PAN/2025 AY : 2016-17 In the event of failure to attend proceeding & non- compliance from the assessee, the Ld. AO completed the assessment ex-parte u/s 144 of the Act to the best of his judgement by making three separate additions

M/S R. S. SHETYE & BROS,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

In the result, the appeal filed by the assessee is partly allowed

ITA 37/PAN/2023[2016-17]Status: DisposedITAT Panaji27 Feb 2026AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 3

143(2) and u/sec 142(1) of the Act are issued calling for the explanations and evidences to substantiate the claims made in the return of income filed. Whereas the assessee has filed the information and details from time to time. The assessing officer on perusal of financial statements find that the assessee has offered interest on FD and IDBI

DINKAR KASHIMATH PATIL,MARCELA vs. INCOME TAX OFFICER-W-1(3),PANAJI, PANAJI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 10/PAN/2025[2018-19]Status: DisposedITAT Panaji04 Apr 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.10/Pan/2025 (A.Y. 2018-19 ) Dinkar Kashimath Patil, Vs National Faceless H.No.322/3,Ganpatiwada, Assessment Centre, . Near Graceland,Khandola, Delhi. Marcela, Ponda-403107, . Goa. Pan/Gir No. Ajjpp9976E (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144Section 194I

TDS was deducted under section 194IA of the Act The Assessing Officer has reason to believe that the income has escaped assessment and issued notice u/sec148 of the Act. And further notice u/sec142(1) of the Act was issued to furnish the details. Since, no explanations/details were filed, the AO considering the information available on record has invoked the provisions

RYATAR SAHAKARI SAKKARE KARKHANE NIYAMIT.,HUBLI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1. BIJAPUR., BIJAPUR

Appeals are allowed for statistical purposes in above terms

ITA 152/PAN/2015[2005-06]Status: DisposedITAT Panaji13 Jul 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

For Appellant: -None-For Respondent: Shri N. Shrikanth
Section 143(3)Section 194CSection 201(1)Section 40

143(3) wherein various additions had been made by invoking the provisions o f sec.40(a)(ia) of the act on account of non-deduction of TDS. It was the submission that one of the main issues was in respect of non- deduction of TDS u/s 194C in respect of payments made to the cane harvesters and cane transporters