Section 40(a)(ia) Disallowance Unjustified if AO failed to Establish Section 194C Applicability

RSD Natural Resources Private Ltd. Vs DCIT (ITAT Kolkata) Introduction: In a notable ruling, the ITAT Kolkata addressed the case of RSD Natural Resources Pvt. Ltd. vs DCIT, focusing on the applicability of Section 194C and the subsequent disallowance under Section 40(a)(ia) of the Income Tax Act. This case highlights crucial aspects of tax compliance and jurisdictional authority in the Indian tax system, offering significant insights for taxpayers and professionals alike. Detailed Analysis Background of the Case: RSD Natural Resources Pvt. Ltd. filed its return of income for the assessment yea...