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
disallowance under
Section 40(a)(ia) of the Act is still applicable.
The High Court observed that the expression
2
2025:UHC:5945-DB
‘tax deductible at source under Chapter XVII-
B’ occurring in Section 40(a)(ia) of the Act
has to be understood as tax deductible at
source under the appropriate provision of
Chapter XVII
