Wrong TDS Section Not Basis for Disallowance – Sec 40(a)(ia) Inapplicable to Short Deduction (194C vs 194J)

DCIT Vs Halliburton Off Shore Services Inc. (ITAT Delhi) Wrong TDS Section Not Ground for Disallowance – Short Deduction U/s 194C vs 194J Not Hit by Sec.40(a)(ia) The ITAT Delhi partly allowed Revenue’s appeal and upheld relief granted by CIT(A), holding that expenditure cannot be disallowed u/s 40(a)(ia) merely because TDS was deducted under a different section (u/s 194C instead of 194J). The AO had disallowed professional fee expenses alleging incorrect TDS deduction, but CIT(A) deleted the addition relying on jurisdictional High Court ruling in Samsung Heavy Industries. The Tribunal obs...