Appeals are dismissed
Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO
iii) Whether the Tribunal is right in law in overlooking the established principle of ‘generalia specialibus non derogant’ vis-à- vis the specific provisions of Sec.194A(3)(viia)(b) and general provisions of Sec.194A(3)(v) of the Act? 3 (iv) Whether the tribunal was correct in not appreciating the fact that the provision of Section 194A(3