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 thereon.
The grounds raised by the assessee are
allowed.”
5.
Learned counsel for the appellant submitted
that admittedly this is a case pertaining to short
deduction of T.D.S. The T.D.S. was deducted by the
assessee under Section 194C at the rate of 2 percent,
instead of deduction under Section 194J at the rate of
10 percent, therefore, the Assessing