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Year-End Provisions Trigger TDS – ITAT Upholds Default but Grants Relief Window
Case Law Details
- Case Name
- Artha Real Estate Corporation Limited Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Bangalore
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Artha Real Estate Corporation Limited Vs DCIT (ITAT Bangalore)
Year-End Provisions Trigger TDS – ITAT Upholds Default but Grants Relief Window
In Artha Real Estate Corporation Ltd., the Bangalore ITAT dealt with whether TDS is required on year-end provisions and consequent treatment as assessee in default u/s 201.
The assessee argued that:
Provisions were mere book entries,
Liability had not crystallized, and
Entries were reversed in the next year, with TDS deducted later on actual payment.
The ITAT rejected this contention and held:
Payee, nature, and amount were identif...
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