Section 40(a)(ia) Disallowance Remanded While Subcontract Expenses Upheld

Chamunda Electrical Pvt. Ltd. Vs ACIT (ITAT Ahmedabad)

ITAT Ahmedabad Upholds ₹1.21 Cr Subcontract Expense Disallowance — 40(a)(ia) Issue Remanded for Fresh Verification

Assessee, a GETCO contractor, appealed against  CIT(A), NFAC, order upholding disallowances made by AO in assessment u/s 143(3).  AO had disallowed (i) ₹1,20,000/- as ROC expenses on increase of share capital, (ii) ₹1,21,15,000/- as subcontract expenses, and (iii) ₹15,33,536/- u/s 40(a)(ia) for non-deduction of TDS.

Tribunal noted that the first ground relating to ROC fees was not pressed

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