Disallowance u/s. 40(a)(ia) are outside the jurisdiction of section 154

Sri Sachin Sharma Vs ACIT (ITAT Ranchi)

A perusal of provisions of section 194C of the Act shows that a person is liable to deduct TDS when a contract for work is of an amount more than Rs.30,000/- or where payment for work is made to a person more than Rs.75,000/- during the financial year. The Assessing Officer has brought no material on record to show that either of the above condition was satisfied in the instant case. Therefore, it is not open to the Assessing Officer in a proceedings u/s.154 of the Act to hold that the

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