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
2 percent,
instead of deduction under Section 194J at the rate of
10 percent, therefore, the Assessing Officer invoked the
provision under Section 40(a)(ia) of the Income Tax
Act, 1961. In order to buttress his argument, learned
counsel
for
appellant
placed
reliance
upon
the
judgment rendered by High Court of Kerala in the case
of “Commissioner of Income
