Section 194C(6) & (7) cannot be read together to attract section 40(a)(ia) disallowance

Shri Gopinathan Vs ITO (ITAT Chennai)

It is not the case of the Department that the Assessing Officer has omitted to consider the claim of expenses and thereby passed the rectification order under section 154 of the Act. In this case assessment was reopened under section 147 of the Act and during the course of reassessment proceedings, after verification of books of accounts, bank account copies and sales tax return and considering the volume of transaction and the nature of trade, the Assessing Officer disallowed 15% of the

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