Section 40(a)(i) not applicable if TDS is deducted & paid within prescribed time

Ayesa Ingenieria Y Arquitectura Vs ACIT (ITAT Delhi)

The case of Ayesa Ingenieria Y Arquitectura (the “assessee”) versus ACIT (Assistant Commissioner of Income Tax) involved two separate final assessment orders for the assessment years 2020-21 and 2021-22, passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961. These orders were based on the directions of the Dispute Resolution Panel (DRP). The assessee, a company registered in Spain, operated in India through its branch office, providing engineering consultancy services. The branch office solely operat

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