Section 154 Rectification Set Aside as Section 40(a)(ia) TDS Issue Was Debatable: ITAT Delhi

Advertisement Maya Buildcon Pvt. Ltd Vs DCIT (ITAT Delhi) The appeal before the ITAT Delhi arose from the order dated 19.11.2025 passed by the Commissioner of Income Tax (Appeals)/Addl./JCIT(A), Gwalior for Assessment Year 2017-18 in proceedings under Section 154 of the Income-tax Act, 1961. The assessee challenged the rectification order dated 21.03.2024 passed by the Assessing Officer and upheld by the lower appellate authority, whereby a disallowance of ₹26,56,715 under Section 40(a)(ia) was made on the ground of non-deduction of TDS on interest payments made to an NBFC. Both parties r...