Section 40(a)(ia) Addition Set Aside Due to Unverified Threshold Applicability

Ramaniyam Real Estates Private Limited Vs ACIT (ITAT Chennai) Section 40(a)(ia) Disallowance Not Automatic: ITAT Remands Issue Where Payments May Be Below TDS Threshold The Chennai Bench of the ITAT, in Ramaniyam Real Estates Pvt. Ltd. v. ACIT (AY 2018-19), dealt with disallowance of expenses under section 40(a)(ia) for alleged non-deduction of TDS on payments towards rent, professional fees, wages and AMC charges aggregating to ₹47.88 lakh. The AO had mechanically disallowed 30% of the expenditure (₹14.36 lakh) on the ground that the assessee failed to produce evidence justifying non-dedu...