Case Law Details
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 year 2015-16, declaring a total income of Rs. 42,66,457/-. The case was selected for scrutiny, and the Assessing Officer (AO) issued a notice under Section 143(2). The AO concluded that the assessee had paid clearing charges without deducting TDS under Section 194C, leading to a disallowance of Rs. 52,86,164/- under Section 40(a)(ia).
Assessee’s Appeal: The assessee challenged this disallowance before the CIT(A), Patna, who upheld the AO’s decision. Consequently, the assessee appealed to the ITAT Kolkata, raising several grounds, including the jurisdiction of CIT(A) Patna and the appropriateness of the disallowance under Section 40(a)(ia).
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