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
13. The only issue is to be decided in this
appeal of the assessee is whether the
provisions of section 40(a)(ia) of the Act
could be made applicable for short deduction
of tax at source.
14. We have heard the rival submission and
perused the material available on record. It is
not in dispute that the assessee made
