TRIVIDH CORPORATION,SURAT vs. PR. CIT-2, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.86/Srt/2020 ("नधा"रणवष" / Assessment Years: (2015-16) (Virtual Court Hearing) Trividh Corporation, Vs. The Pcit, Surat. Tp No.25, Fp No.103, Aashtha Medicare & Residency, Abrama Road, Mota Varachha, Surat-395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahft0894N (Assessee) (Respondent) Assessee By : Shri Rajesh Upadhyay, Ar Revenue By : Shri S. T. Bidari, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 13/05/2021 घोषणाक"तार"ख/Date Of Pronouncement : 24/05/2021 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By The Assessee, Pertaining To The Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income Tax, Surat [In Short “The Ld. Pcit”], Under Section 263 Of The Income Tax Act, 1961, [Hereinafter Referred To As The “Act”]. Grievances Raised By The Assessee Are As Follows: “1. Ld. Principal Cit Has Erred In Law & On Facts To Invoke Provisions Of Section 263 Of The Act & Finally ‘Set-Aside’ Ao’S Assessment Completed U/S 143(3) Of The Act & Also Direct The Ao To Frame The Assessment ‘Denovo’.” 2. The Relevant Material Facts, As Culled Out From The Material On Record, Are As Follows. The Assessee Before Us Is A Firm. It Has Filed Its Return Of Income For Assessment Year 2015-16 On 13.10.2015 Declaring Total Income At Rs. 4,42,80,220/-. The Assessee`S Case Was Selected For Scrutiny & Statutory Notice U/S 143(2) Of The Act Was Issued To The Assessee. The Assessee Is Engaged In The Business Of Construction & Project Development Activities. The Id Assessing Assessment Years.2015-16 Trividh Corporation Officer (Herein After Referred To ‘Ao’) Finalized The Assessment U/S 143(3) Of The Income Tax Act, On 11.12.2017, Accepting The Returned Income Of The Assessee.

69, section 69A, section 696, section 69C or section 69D, at the rate of thirty per cent. Despite such facts and circumstances and specific provisions of law in section 115BBE(2) of the Act, Assessing Officer has completed assessment determining total income at Rs.4,42,80,220/- and thereby allowing your erroneous claim to the tune of Rs.32

SHRI BALAJI J BHAGNURE,SURAT vs. INCOME TAX OFFICER, WARD-2(3)(1), SURAT

In the result, appeal of the assessee is allowed partly in above terms

Bench: Shri Pawan Singhआ.अ.सं./Ita No.250/Srt/2022 (Ay 2012-13) (Hearing In Virtual Court) Shri Balaji J. Bhagnure Income Tax Officer, 98, Santkrupa Society, In Ward-2(3)(1) Aayakar Vs Lane Of Mahadev Mandir, Bhawan, Majura Gate, Godadara Devadh Road, Surat-395001 Godadara, Surat-394210 Pan No: Alkpb 8794 M अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Sapnesh R Sheth, C.A राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 27.12.2022 उ"घोषणा क" तार"ख/Date Of 27.12.2022 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre [For Short To As “Nfac/ Ld.Cit(A)”] Dated 26.07.2022 For Assessment Year 2012-13, Which In Turn Arises Out Assessment Order Passed By Assessing Officer Under Section 144 R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 11.11.2019. The Assessee Has Raised The Following Grounds Of Appeal: - “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Assessing Officer Has Erred In Reopening Assessment By Issuing Notice U/S 148 Of The I.T. Act 1961. Sh. Balaji J Bhagnure 2. On The Facts & Circumstances Of The Case As Well Law On The Subject, The Learned Assessing Officer Has Erred In Passing Ex-Parte Order U/S 144 Of The I.T. Act.

69,441/- and deducted TDS of Rs. 3,694/- under section 194C. The Assessing Officer made addition of Rs. 738,882/-, which

THE ITO, WARD-1,, NA vs. ARIVS.SHRI ANILKUMAR AMRUTLAL CHAHWALA, NAVSARI

In the result, this ground of appeal is rejected

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.2078/Ahd/2010 िनधा"रणवष"/Assessment Year: 2006-07 आ.अ.सं./I.T.A No.1003/Ahd/2011 िनधा"रणवष"/Assessment Year: 2007-08 The Income Tax Officer, Vs. Shri Anil Kumar Amrutlal Chahwala, Ward-(1), Navsari. 102, Trimurti Complex, Vijalpore, Navsari. [Pan: Abnpc 6308 F] अपीलाथ" / Appellant ""थ"/Respondent

TDS (tax deduction at source) as required under section 194C was of Rs. 5,28,86,206/-, which consist of Rs. 1,68,29,000/- by Padmavati Gems to 187 Labour Contractor and Rs. 3,60,57,206/- by Parth Corporation to 258 Labour Contractor. Thus, the assessing officer disallowed Rs. 5,28,86,206/-on account of labour expenses

ENGINEERING PROFESSIONAL CO. PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.541/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Engineering Professional Co. Pvt. Ltd., Vs. The Pcit -1, 444, Royal Arcade, Opp. Sarthana Zoo, Surat Varachha Road, Near Sarthana Jakatnaka, Surat – 395006, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabce0313Q (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ravi Kant Gupta, Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 19/02/2025

69 of the paper books, are as under: “List of Sub-Contractors for the period from: 1-Apr-2017 to 31-Mar-2018 Sr. Name PAN Amount No. 194C - Sub Contractor: 1 Akash Awsthi (TDS Deducted) AYLPA4773H 460.000 2 AT Electro Mechenical (TDS Deducted) BTLPS5343D 650,000 3 Cheian Valjibhai Maniya(TDS Deducted) CNVPM4860Q 1,575,743 4 Deepak Arora

RAJGREEN INFRALINK LLP,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE - 1(3), SURAT

In the result, the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.257 & 375/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Rajgreen Infralink Llp Deputy Commissioner Of 29-30, Sai Baba Shraddha Nagar, Income Tax, Circle-1(3) Nr. Choksi Wadi, New Rander Road, Surat, Aaykar Bhavan, Adajan, Surat-395009 Majura Gate, Surat-395001 Pan No. Aavfr 8064 N Assistant Commissioner Of Income- Rajgreen Infralink Llp Vs Tax, Circle-1(3), Surat, Room No. 29-30, Sai Baba Shraddha 301, 3Rd Floor, Anavil Business Nagar, Nr. Choksi Wadi, Centre, Hazira Road, Adajan, New Rander Road, Adajan, Surat-395009 Surat-395009 Pan No. Aavfr 8064 N अपीलाथ"/Appellant ""थ" /Respondent

TDS in short) and the closing balance as on 31.03.2018 and complete pdf folder consisting of duly signed of confirmation of ITR, relevant bank statement of the depositors were furnished. On furnishing such details, the Assessing Officer has not made any enquiry of his own either issuing notice under section 133(6) or 131 of the Act. The assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIR - 1(3), SURAT vs. RAJGREEN INFRALINK LLP, SURAT

In the result, the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.257 & 375/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Rajgreen Infralink Llp Deputy Commissioner Of 29-30, Sai Baba Shraddha Nagar, Income Tax, Circle-1(3) Nr. Choksi Wadi, New Rander Road, Surat, Aaykar Bhavan, Adajan, Surat-395009 Majura Gate, Surat-395001 Pan No. Aavfr 8064 N Assistant Commissioner Of Income- Rajgreen Infralink Llp Vs Tax, Circle-1(3), Surat, Room No. 29-30, Sai Baba Shraddha 301, 3Rd Floor, Anavil Business Nagar, Nr. Choksi Wadi, Centre, Hazira Road, Adajan, New Rander Road, Adajan, Surat-395009 Surat-395009 Pan No. Aavfr 8064 N अपीलाथ"/Appellant ""थ" /Respondent

TDS in short) and the closing balance as on 31.03.2018 and complete pdf folder consisting of duly signed of confirmation of ITR, relevant bank statement of the depositors were furnished. On furnishing such details, the Assessing Officer has not made any enquiry of his own either issuing notice under section 133(6) or 131 of the Act. The assessee

THE DCIT, CIRCLE-1,, BHARUCH vs. M/S. GUJARAT NARMADA VALLEY FERTILIZERS & CHEMICALS LTD.,, BHARUCH

In the result, this ground of appeal is also dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.431/Srt/2018 (Ay 2007-08) & (Hearing In Virtual Court) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Bharuch, Fertilizers & Chemicals Vs Above Bank Of Baroda, Ltd. Station Road, Bharuch- P.O. Narmada Nagar, 320001 Dist. Bharuch-392015 Pan : Aaacg 8372 Q अपीलाथ"/Appellant ""यथ" /Respondent आ.अ.सं./Ita No.432/Srt/2018 & ""या"ेप/C.O. No.12/Srt/2021 [A/O Ita No.432/Srt/2018] (Ay 2012-13) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Fertilizers & Chemicals Ltd. Vs Bharuch, Above Bank Of P.O. Narmada Nagar, Dist. Baroda, Station Road, Bharuch-392015 Pan : Aaacg 8372 Q Bharuch-320001 अपीलाथ"/Appellant ""यथ" /Respondent/Co- Objector

69,74,652/- made under section 40(a)(ia) of the IT Act considering discount given to the dealers is not in the nature of commission liable for deduction of tax at sources u/s 194H of the IT Act. 3. On the facts and in the circumstances of the case and in law, the Ld. CIT (Appeals) erred by deleting

THE DCIT, CIRCLE-1,, BHARUCH vs. M/S. GUJARAT NARMADA VALLEY FERTILIZERS & CHEMICALS LTD.,, BHARUCH

In the result, this ground of appeal is also dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.431/Srt/2018 (Ay 2007-08) & (Hearing In Virtual Court) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Bharuch, Fertilizers & Chemicals Vs Above Bank Of Baroda, Ltd. Station Road, Bharuch- P.O. Narmada Nagar, 320001 Dist. Bharuch-392015 Pan : Aaacg 8372 Q अपीलाथ"/Appellant ""यथ" /Respondent आ.अ.सं./Ita No.432/Srt/2018 & ""या"ेप/C.O. No.12/Srt/2021 [A/O Ita No.432/Srt/2018] (Ay 2012-13) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Fertilizers & Chemicals Ltd. Vs Bharuch, Above Bank Of P.O. Narmada Nagar, Dist. Baroda, Station Road, Bharuch-392015 Pan : Aaacg 8372 Q Bharuch-320001 अपीलाथ"/Appellant ""यथ" /Respondent/Co- Objector

69,74,652/- made under section 40(a)(ia) of the IT Act considering discount given to the dealers is not in the nature of commission liable for deduction of tax at sources u/s 194H of the IT Act. 3. On the facts and in the circumstances of the case and in law, the Ld. CIT (Appeals) erred by deleting

CHIRAGBHAI S. GADHIYA,SURAT vs. I.T.O., WARD-3(2)(6),, SURAT

In the result, this appeal of assessee is allowed

Bench: Shri Pawan Singh(Physical Hearing) Chiragbhai S. Gadhiya, I.T.O., 79, Mani Nagar Society, Nana Ward-3(2)(6), Vs. Varachha, Nr. Sarthana Jakat Naka, Surat. Surat-395006. Pan No. Ajypg 7927 K Appellant/ Assessee Respondent/ Revenue

TDS form was furnished. On the basis of aforesaid submission, the assessee requested to delete the addition under Section 68 of the Act of Rs. 24,91,375/-. 4. The ld. CIT(A) after considering the submission of assessee held that the assessee claimed that he has received cash from various parties, however, no documentary evidence was furnished before

ARJUNSINH HARISINH THAKOR,SURAT vs. INCOME TAX OFFICER, BARDOLI

In the result, grounds No

Bench: Shri Pawan Singh(Physical Hearing) Arjunsinh Harisinh Thakor, I.T.O., 1 Thakor Niwas, Zanda Chowk, Ward-1, Vs. Tarasadi Road, Kosamba, Bardoli. Surat-394120. Pan No. Aabpt 1270 G Appellant/ Assessee Respondent/ Revenue

69, 69A, 69B, 69C or 69D whether the income is offered by the assessee in the return of income or assessment is made by Assessing Officer under these Sections. The amendment was brought to plug the loophole of taxing the unexplained cash in demonetized currency. The argument of assessee that the amendment brought by legislation is in contradiction with

JAVAHARLAL S DHARIWAL,SURAT vs. ITO WARD 1(2)(2), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singhआ.अ.सं./Ita No.203/Srt/2020 (Ay 2013-14) (Hearing In Physical Court) Javaharlal S Dhariwal Income Tax Officer, 886 Old Gidc, Nr. Bank Of Ward-1(2)(2), Surat-395001 Vs Baroda, Katargam, Surat- 395004 Pan No: Aaypd 4207 G अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Mahul Shah, C.A राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 02.02.2023 उ"घोषणा क" तार"ख/Date Of 28.04.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-2, Surat [For Short To As “Ld.Cit(A)”] Dated 30.01.2020 For Assessment Year 2013- 14, Which In Turn Arises Out Assessment Order Passed By Income-Tax Officer-Ward-1(2)(2), Surat/Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 12.02.2016. The Assessee Has Raised The Following Grounds Of Appeal:- “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of Assessing Officer In Making A Disallowance Of Rs.3,45,378/- U/S 40(A)(Ia) Of The It Act 1961. Javaharlal S Dhariwal 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject The Learned Cit(A) Has Erred In Partly Confirming The Action Of Assessing Officer By Sustaining The Disallowance Of Rs.2,46,915/- Out Of Total Disallowance Of Rs.4,93,830/- On Account Of Machinery Salary Expenses. 3. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of Assessing Officer In Making Addition Of Rs.3,95,466/- Being Interest Expenses Claimed U/S 57 Of The Act.

TDS) as required under section 194C 2 Javaharlal S Dhariwal r.w.s. 194A of the Act. The assessee was given show cause by the assessing officer as to such expenses may not be disallowed. The assessing officer recorded that no response was made nor any detailed like PAN, or addresses of the parties were furnished. The Assessing Officer in absence

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT CHEMICAL PORT TERMINAL CO.LTD.,, BHARUCH

In the result, Cross Objection appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.1501/Ahd/2014 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Gujarat Chemical Port Terminal V The Commissioner Of Income Tax, Vadodara. Company Ltd., S Po Lakhigam, Via Dahej, . Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2998/Ahd/2014 "नधा"रण वष"/Assessment Year: 2010-11 The Deputy Commissioner Of Income V M/S.Gujarat Chemical Port Tax, Circle-1(1), Baroda. S Terminal Company Ltd., . Po Lakhigam, Via Dahej, Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent Cross Objection No.30/Ahd/2015 (Arising Out Of Ita No.2998/Ahd/2014) "नधा"रण वष"/Assessment Year: 2010-11 M/S.Gujarat Chemical Port Vs. The Deputy Commissioner Of Terminal Company Ltd., Income Tax, Circle-1(1), Po Lakhigam, Via Dahej, Baroda. Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent

69,83,390/- less TDS Rs.38,48,436/-/-) payable on the loan received from Reliance Industries Limited. (RXL) was capatilized and was added to loan amount. Since the amount of interest was not actually paid and the loan amount to that extent increased, the interest amount so claimed u/s 36(l)(iii) was required to be disallowed. Not doing this

M/S. GUJARAT CHEMICAL PORT TERMINAL CO.LTD.,,BHARUCH vs. THE CIT-I, BARODA

In the result, Cross Objection appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.1501/Ahd/2014 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Gujarat Chemical Port Terminal V The Commissioner Of Income Tax, Vadodara. Company Ltd., S Po Lakhigam, Via Dahej, . Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2998/Ahd/2014 "नधा"रण वष"/Assessment Year: 2010-11 The Deputy Commissioner Of Income V M/S.Gujarat Chemical Port Tax, Circle-1(1), Baroda. S Terminal Company Ltd., . Po Lakhigam, Via Dahej, Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent Cross Objection No.30/Ahd/2015 (Arising Out Of Ita No.2998/Ahd/2014) "नधा"रण वष"/Assessment Year: 2010-11 M/S.Gujarat Chemical Port Vs. The Deputy Commissioner Of Terminal Company Ltd., Income Tax, Circle-1(1), Po Lakhigam, Via Dahej, Baroda. Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent

69,83,390/- less TDS Rs.38,48,436/-/-) payable on the loan received from Reliance Industries Limited. (RXL) was capatilized and was added to loan amount. Since the amount of interest was not actually paid and the loan amount to that extent increased, the interest amount so claimed u/s 36(l)(iii) was required to be disallowed. Not doing this

CHANCHALBEN DAHYABHAI PATEL,DAMAN vs. ITO, DAMAN

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT

In the result, Revenue’s appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

TDS made on such interest and the amount received and repaid during the year. Such details are recorded by ld CITA) at page No. 18 & 19 of his order. The assessee also stated that the assessing officer considered only peak of all transaction and made addition of Rs. 4.15 Crore in AY 2010-11 and Rs. 2.14 Crore

CHANCHALBEN DAHYABHAI PATEL,DAMAN vs. INCOME TAX OFFICER, DAMAN

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

DHARMESH DAMJIBHAI PATOLIYA,SURAT vs. ITO, WARD2(2)(1), SURAT

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

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.487/Srt/2024 Assessment Year: (2014-15) (Hybrid Hearing) Dharmesh Damjibhai Patoliya Vs. Ito, 101 Gandamaya Apartment Ward – 2(2)(1), Matrukrupa Society, Kamrej Surat Charrasta Opp. Azim Hospital, Tal: Kamrej, Surat-395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahzpp1276F (Appellant) (Respondent) Appellant By Shri P.M. Jagasheth, Ca Respondent By Ms. Neerja Sharma, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 17/07/2025

69,338/- on loan to these non-banking institutions. It was found that no TDS has been deducted on the interest payment. All the financial institutions are non-banking financial institution and TDS has to be deducted as per the provisions of section

MICRO INKS PVT. LTD., ( FORMERLY KNOWN AS MICRO INKS LTD.),VAPI vs. THE INCOME TAX OFFICER, ( INTL. TAXN.), SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.2375/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 The Income Tax Officer, V Micro Inks Limited, (International Taxation), Surat. S. Bilakhia House, Muktanand Marg, Chala, Vapi – 396 191. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2707/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 Micro Inks Limited, V The Income Tax Officer, Bilakhia House, Muktanand S. (International Taxation), Marg, Chala, Vapi – 396 191. Surat. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Gopala Krishnan – Ca राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr सुनवाईकीतारीख/ Date Of Hearing: 06.02.2020 उ"घोषणाक"तार"ख/Pronouncement On: 14.02.2020

section 9(1)(vb) of the Act. We thought it fit to dispose of the same by the present consolidated order. ITO,(Int. Taxation), Surat Vs. Micro Inks Ltd.: Vice-Versa /ITA No’s.2375 & 2707/AHD/2014 for A.Y. 2012-13 Page 4 of 27 8. The ld.Departmental Representative(DR) appearing on behalf of the Revenue relied upon the order