THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S D.M.L. EXIM PVT. LTD.,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

disallowance of Rs. 9,73,33,826/- being export commission paid to non-resident agents, u/s. 40(a)(ia) on the ground of non-deduction of TDS. The case of the Revenue is this that the person making payment to the non-resident would be liable to be deducted tax under Section 194H

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S DML EXIM PVT. LTD.,, RAJKOT-GUJARAT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. D.M.L. WORLD TRADE PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

THE DCIT, CIRCLE 2(1), RAJKOT-GUJARAT vs. SMT MEENABEN H LAKHANI, RAJKOT-GUJARAT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

THE DCIT, CIRCLE-1 (2), RAJKOT vs. SHRI NARENDRA NANJIBHAI DAVDA, RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. DRB COMMODITIES PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. DRB COMMODITIES PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H would come into play only when the payers has not deducted the tax at source

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

section 194H of the Income tax Act 1961. Therefore the\nclaim of payment of commission amounting to Rs.3,00,000/- was disallowed

HARDIKKUMAR MAGANBHAI THUMAR,RAJKOT vs. THE INCOME TAX OFFICER WARD 1(1)(1), RAJKOT

In the result, the assessee appeal is allowed for statical purpose

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 625/Rjt/2025 "नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Hardikkumar Maganbhai Thumar Vs. The Income Tax Officer, Ward Jetalsar, Jetalsar Post, Jetpur Rajkot- 1(1)(1),/Rkt. 360360.Gujarat It Office, New Aaykar Bhavan, Vatiaka, Rajkot. Gujarat 360360 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Axupt8837F (Appellant) (Respondent) Appellant By : Shri Kishor Gheewala, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23 / 12 /2025 Date Of Pronouncement : 05 / 01 /2026

194H as commission/brokerage. Assessee failed to produce satisfactory evidences to substantiate the facts. As per the section 40(a)(ia) of the Income Tax Act, being disallowance