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Case Law Details

Case Name : Rahul Udyog Vs ITO (ITAT Nagour)
Appeal Number : ITA No. 306/Nag./2017
Date of Judgement/Order : 10/06/2022
Related Assessment Year : 2013–14
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Rahul Udyog Vs ITO (ITAT Nagour)

Introduction: The article delves into the case of Rahul Udyog versus ITO, as heard by ITAT Nagpur. The dispute revolves around disallowances related to TDS and various business expenses. This analysis aims to uncover the intricacies of the case, emphasizing the arguments presented by both parties.

Detailed Analysis:

The contention arises from disallowances on Hamali expenses, where the ld.CIT(A) sustained disallowances under section 40(a)(ia) for non-deduction of TDS on payments exceeding Rs. 75,000/-. The appellant’s defense emphasizes payments made to a group of Hamali workers, challenging the necessity of TDS on such transactions. The ld.CIT(A) upheld the disallowance, citing non-submission of supporting documents.

In a similar vein, expenses related to Jalau Lakdi and Bardana purchases faced disallowance under section 40A(3). The ld CIT(A) questioned the justification for cash payments, emphasizing the absence of supporting documentary evidence. The appellant argued for exceptions under Rule 6DD(e)(i) concerning payments to Adivasi families.

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