Commissioner Of Income Tax International Taxation 3 vs. Samsung Heavy Industries Company Limited
Appeal stands dismissed
ITA/10/2024HC Uttarakhand10 Jul 2025
Bench: HON'BLE MR JUSTICE G. NARENDAR,HON'BLE MR. JUSTICE ALOK MAHRA
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 194CSection 194JSection 260Section 40
4
2025:UHC:5945-DB
the Hon'ble Calcutta High Court and decision
rendered by the Hon’ble Delhi High Court
referred
(supra)
and
hold
that
section
40(a)(ia)
of
the
Act
cannot
be
made
applicable for short deduction of tax at
source. Accordingly, the ld AO is hereby
directed to delete the disallowance thereon.
The grounds raised
