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
Section 40(a)(ia) of the Income Tax Act, 1961 cannot
be made applicable to short deduction of tax at source
and the disallowance made was directed to be deleted.
This finding of learned Income Tax Appellate Tribunal is
6
2025:UHC:5945-DB
based on the judgment rendered by Hon’ble Calcutta
High Court in the case of Commissioner
