M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JCIT TDS, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

section of the IT Act has been passed to hold the appellant as "Assessee in default" for non deduction of TDS. As such, the impugned penalty order passed U/s 271C cannot be sustained to the extent that the revenue department has nowhere ever alleged the assessee to be in default for non deduction of TDS. 4. For that

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS being unknown, interest was incapable of calculations, it could be said that interest under section 201(1A) was not leviable - Held, yes - 13. We also find substantial merit in the second submission of the learned counsel for the assessee, namely, that interest under section 201(1A) was not leviable because the date of payment of tax deducted at source

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS being unknown, interest was incapable of calculations, it could be said that interest under section 201(1A) was not leviable - Held, yes - 13. We also find substantial merit in the second submission of the learned counsel for the assessee, namely, that interest under section 201(1A) was not leviable because the date of payment of tax deducted at source

K M MEMORIAL HOSPITAL & RESERCH CENTRE (P) LTD,BOKARO vs. ACIT, CIRCLE-1,, HAZARIBAG

In the result, this ground of appeal of assessee is partly allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS under Section 194C of the Act but since it 2 K.M. Memorial Hospital Vs ACIT has failed to deduct the same. The expenditure claimed at ₹ 3,00,000/- has to be disallowed under Section 40(a)(ia) of the Act. 6. Aggrieved by the order of ld. CIT(A), this appeal has been preferred before us. During the course

ACIT CIR-1 , DHANBAD vs. M/S BHARAT COKING COAL LTD, DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

M/S BHARAT COOKING COAL LIMITED ,DHANBAD vs. ACIT CIRCLE-1 , DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

M/S P.K.UPADHYAY vs. ITO WARD-3(5), PALAMAU

In the result, the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Manish Borad

section 143(3) on 31.12.2012. The ld. Assessing Officer has determined the total income of the assessee at Rs.3,52,780/-. In the reopened assessment, the ld. Assessing Officer perused the record and recorded a finding that the assessee has debited a sum of Rs.5,11,164/- in the assets side of the balance-sheet on account of time extension

RISHIRAJ HOMES PRIVATE LIMITED,JAMSHEDPUR vs. ITO(TDS), JAMSHEDPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.104, 206 & 207/Ran/2019 (नििाारण वषा / Assessment Year :2013-14, 2014-15 & 2015-16) Rishiraj Homes Private Limited Vs. Ito(Tds), Jamshedpur Contractors Area, Bistupur, Jamshedpur, C/O: Ca Jagdish Khandelwal, 402&403, A.J.Tower, Q. Road, Bistupur, Jamshedpur-831001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaccr 7328 H (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By :Shri Jagdish Khandelwal, Ca(Ar) राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 21/05/2019 घोषणा की तारीख/Date Of Pronouncement 21/05/2019 आदेश / O R D E R These Three Appeals Have Been Filed By The Assessee Against The Separate Order Of Commissioner Of Income Tax (Appeals), Jamshedpur, All Dated 05.11.2018 For The Assessment Years 2013-2014, 2014-2015 & 2015-2016, Respectively. 2. The Sole Issue Involved In All The Thee Appeals Of The Assessee Is That The Cit(A) Erred In Confirming The Order Of Ao Levying Late Fee U/S.234E Of The Act For Delay In Filing Quarterly Statement. 3. Brief Facts Of The Case Are That The Assessee Filed Tds Return In Form No.24Q Financial Year 2012-2013, 2013-2014 & 2014-2015 Relating To Assessment Year 2013-2014, 2014-2015 & 2015-2016, Respectively. Thereafter A Demand Was Raised In All The Three Appeals Under 2

8. Heard the rival contention and perused the material relevant. We find that while deciding the issue against the appellant assessee the ld. CIT(A) has placed reliance on 'Rajesh Kaurani vs. Union of India', 83 Taxmann.com 137 (Guj.) wherein it was held that Section 200A of the Act is a machinery provision providing the mechanism for processing a TDS

INDICO MOTORS PRIVATE LIMITED,JAMSHEDPUR vs. ITO(TDS), JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.324/Ran/2018 (नििाारण वषा / Assessment Year :2013-2014) (Financial Year 2012-2013) Indico Motors Pvt. Ltd. Vs. Ito(Tds), Jamshedpur M-25(P) & 26(P) Ivth Phase, Adityapur Industrial Area, Chamaria, Jamshedpur C/O: Ca Jagdish Khandelwal, 402&403, A.J.Tower, Q. Road, Bistupur, Jamshedpur-831001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aabci 4002 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By :Shri Jagdish Khandelwal, Ca(Ar) राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 21/05/2019 घोषणा की तारीख/Date Of Pronouncement 21/05/2019 आदेश / O R D E R This Appeal Has Been Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals), Jamshedpur, Dated 30.07.2018 For The Assessment Year 2013-2014. 2. The Sole Issue Involved In This Appeal Of The Assessee Is That The Cit(A) Erred In Confirming The Order Of Ao Levying Late Fee U/S.234E Of The Act For Delay In Filing Quarterly Statement. 3. Brief Facts Of The Case Are That The Assessee Filed Tds Return In Form No.24Q Financial Year 2012-2013 Relating To Assessment Year 2013-2014. Thereafter A Demand Was Raised In The Appeal Under Consideration On Account Of Late Filing Fee U/S.234E Of The Act. Thereafter

8. Heard the rival contention and perused the material relevant. We find that while deciding the issue against the appellant assessee the ld. CIT(A) has placed reliance on 'Rajesh Kaurani vs. Union of India', 83 Taxmann.com 137 (Guj.) wherein it was held that Section 200A of the Act is a machinery provision providing the mechanism for processing a TDS

PRAMOD KUMAR MANPURIA,RANCHI vs. DCIT CPC(TDS), GHAZIABAD

In the result, all the three appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

Section 200A of the Income Tax Act, 1961 is prospective in nature, therefore, no computation of late fee or demand or intimation u/s.234E of the Act could be made for TDS deducted in respective statements prior to 01.06.2015 and processed u/s.200A of the Act. I have also gone through the decision of coordinate bench of the Tribunal placed

PRAMOD KUMAR MANPURIA,RANCHI vs. DCIT CPC TDS , GHAZIABAD

In the result, all the three appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

Section 200A of the Income Tax Act, 1961 is prospective in nature, therefore, no computation of late fee or demand or intimation u/s.234E of the Act could be made for TDS deducted in respective statements prior to 01.06.2015 and processed u/s.200A of the Act. I have also gone through the decision of coordinate bench of the Tribunal placed

PRAMOD KUMAR MANPURIA ,RANCHI vs. DCIT CPC TDS , GHAZIABAD

In the result, all the three appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

Section 200A of the Income Tax Act, 1961 is prospective in nature, therefore, no computation of late fee or demand or intimation u/s.234E of the Act could be made for TDS deducted in respective statements prior to 01.06.2015 and processed u/s.200A of the Act. I have also gone through the decision of coordinate bench of the Tribunal placed

PRAMOD KUMAR MANPURIA ,RANCHI vs. DCIT TDS CPC , GHAZIABAD

In the result, all the three appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

Section 200A of the Income Tax Act, 1961 is prospective in nature, therefore, no computation of late fee or demand or intimation u/s.234E of the Act could be made for TDS deducted in respective statements prior to 01.06.2015 and processed u/s.200A of the Act. I have also gone through the decision of coordinate bench of the Tribunal placed

PRAMOD KUMAR MANPURIA ,RANCHI vs. DCIT TDS CPC , GHAZIABAD

In the result, all the three appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

Section 200A of the Income Tax Act, 1961 is prospective in nature, therefore, no computation of late fee or demand or intimation u/s.234E of the Act could be made for TDS deducted in respective statements prior to 01.06.2015 and processed u/s.200A of the Act. I have also gone through the decision of coordinate bench of the Tribunal placed

M/S BHARAT COKING COAL LTD ,DHANBAD vs. ACIT CIRCLE-1 , DHANBAD

In the result, all the captioned appeals are hereby dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.299/Ran/2017 Assessment Year: 2009-10 Acit,Central-1, Dhanbad............................................................……Appellant Vs. M/S Bharat Coking Coal Ltd........................................……...…..…..Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] I.T.A No.123/Ran/2018 Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd........................................................…… Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant C.O No.08/Ran/2018 (In Ita No.299/Ran/2017) Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd..................................................... …Cross-Objector Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant Appearances By: Shri Rinku Singh, Cit- Dr., Appeared On Behalf Of The Appellant. Shri M. K. Choudhary With Devesh Poddar, Adv Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 23, 2023 Date Of Pronouncing The Order : July 07, 2023

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

ACIT CIR-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

In the result, all the captioned appeals are hereby dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.299/Ran/2017 Assessment Year: 2009-10 Acit,Central-1, Dhanbad............................................................……Appellant Vs. M/S Bharat Coking Coal Ltd........................................……...…..…..Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] I.T.A No.123/Ran/2018 Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd........................................................…… Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant C.O No.08/Ran/2018 (In Ita No.299/Ran/2017) Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd..................................................... …Cross-Objector Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant Appearances By: Shri Rinku Singh, Cit- Dr., Appeared On Behalf Of The Appellant. Shri M. K. Choudhary With Devesh Poddar, Adv Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 23, 2023 Date Of Pronouncing The Order : July 07, 2023

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

RAM KUMAR,JAMSHEDPUR vs. ACIT CENTRAL CIRCLE, JAMSHEDPUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 189/Ran/2025 Assessment Year: 2018-2019 Ram Kumar,…………………………………………..Appellant C/O. Ram Bilash Prasad Gupta, Gayatri Niwas, Ekta Colony, Majhi Tola, Adityapur, Jamshedpur-831013, Jharkhand [Pan:Anspk0996Q] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Central Circle, Office Road, Jamshedpur-831001, Jharkhand Appearances By: Shri Akshay Ringasia, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

section 194J was Rs.4,68,868/- and professional receipts were Rs.46,88,681/- for FY 2017-18. During the course of survey operation, the assessee received Rs.14,72,295/- as per receipts of his professional fees from his clinic upto 28.02.2018, which is different from the above amount on which TDS was deducted. Professional receipts were Rs.62

HARDEEP SINGH,JAMSHEDPUR vs. ITO(TDS)J, JAMSHEDPUR

In the result, both the appeals of the assessee are allowed

8. Heard the rival contention and perused the material relevant. We find that while deciding the issue against the appellant assessee the ld. CIT(A) has placed reliance on 'Rajesh Kaurani vs. Union of India', 83 Taxmann.com 137 (Guj.) wherein it was held that Section 200A of the Act is a machinery provision providing the mechanism for processing a TDS