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section 40(a)(ia)

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Karnataka HC Allows Section 263, Distinguishes Plausible View Doctrine

Income Tax : Karnataka High Court allows PCIT's appeal, upholding a Section 263 revision for non-disallowance of commission payments without TD...

July 21, 2025 1194 Views 2 comments Print

Consequences of Non-Compliance to TDS (Section 201)

Income Tax : Understand the penalties, interest, and disallowance of expenditure under Section 201 for failure to comply with TDS provisions in...

July 5, 2025 8271 Views 0 comment Print

Disallowed Expenses While Calculating Profits & Gains of Business or Profession

Income Tax : Learn about disallowed expenses under PGBP in India's Income Tax Act. Understand key sections like 37, 40, and 40A, and their impa...

October 7, 2024 11802 Views 0 comment Print

Disallowances covered under Income-Tax Act and Reporting in Tax Audit

Income Tax : Learn about disallowances under Income Tax Act sections and their reporting requirements in Form 3CD during tax audits. Key provis...

September 29, 2024 11388 Views 0 comment Print

TDS Obligations: Reimbursement of Expenses vs. Fee for Technical Services

Income Tax : Delhi HC rules reimbursements to NRAEs not subject to TDS as "fees for technical services," clarifying scope of Section 9(1)(vii) ...

September 25, 2024 2424 Views 0 comment Print


Latest News


Section 40(a)(ia): Disallowance of expenditure for non-deduction of tax at source on payment made to resident

Income Tax : Section 40(a)(ia) is amended via Finance (No. 2) Act, 2014 to restrict the amount of disallowance for non-deduction of tax to 30% ...

January 21, 2018 151173 Views 3 comments Print

Change in provisions related to disallowance of expenditure on account of non-compliance with TDS provisions : Budget 2010-11

Income Tax : The existing provisions of section 40(a)(ia) of Income-tax Act provide for the disallowance of expenditure like interest, commissi...

February 26, 2010 1080 Views 0 comment Print


Latest Judiciary


Notional Interest Addition Deleted Because Only Real Income Can Be Taxed: ITAT Delhi

Income Tax : ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional in...

May 10, 2026 270 Views 0 comment Print

No TDS on Foreign Agent Commission for Services Rendered Abroad; ITAT Deletes Section 40(a)(i) Disallowance

Income Tax : The Tribunal held that commission paid to foreign agents for services rendered outside India is not taxable in India. Consequently...

April 29, 2026 267 Views 0 comment Print

No Adhoc Disallowance of Commission on Assumptions Without Specific Defects: ITAT Delhi

Income Tax : The issue was whether commission payments were genuine business expenses. The Tribunal held that disallowance based on non-respons...

April 29, 2026 312 Views 0 comment Print

Charitable Trust as Pass-Through Entity: ITAT Deletes Interest Disallowance Rejects 8% Profit Estimation

Income Tax : The Tribunal held that interest expenses cannot be disallowed when the trust merely facilitates transactions and costs are reimbur...

April 27, 2026 126 Views 0 comment Print

Consistency Over Technicalities – ITAT Allows Actuarial Pension Provision & Rejects Mechanical Disallowances

Income Tax : Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical ...

April 24, 2026 315 Views 0 comment Print


Latest Notifications


Disallowance for failure to withhold tax- Sec.195 rw Sec. 40(a)(i)

Income Tax : Circular No. 3/2015 Section 40(a)(i) of the Act stipulates that in computing the income chargeable under the head "Profits or gain...

February 12, 2015 5517 Views 0 comment Print

S. 195 AOs to tax taxable part of sum paid to NR for TDS default

Income Tax : Sub: Deduction of tax at source under Section 195 read with Sections 201 of the Income-tax Act, 1961 relating to payment made to a...

February 26, 2014 15029 Views 0 comment Print

CBDT circular on Section 40(a)(ia)-TDS Disallowance

Income Tax : Circular No. 10/DV/2013-Income Tax It has been brought to the notice of the Board that there are conflicting interpretations by j...

December 16, 2013 21473 Views 0 comment Print


No disallowance u/s. 40(a)(ia) when tax on income already paid by deductee: ITAT Pune

July 29, 2025 1287 Views 0 comment Print

ITAT Pune held that disallowance under section 40(a)(ia) of the Income Tax Act cannot be sustained interest income is already reflected in the return of the deductee and tax is already paid on the same. Accordingly, appeal allowed to that extent.

Karnataka HC Allows Section 263, Distinguishes Plausible View Doctrine

July 21, 2025 1194 Views 2 comments Print

Karnataka High Court allows PCIT’s appeal, upholding a Section 263 revision for non-disallowance of commission payments without TDS, citing AO’s lack of explicit inquiry.

Deduction 80P admissible as presence of nominal and associate members lawful under KCSA

July 12, 2025 450 Views 0 comment Print

ITAT Bangalore held that eligibility u/s. 80P should be assessed in the light of the relevant state cooperative law. Under Karnataka Cooperation Societies Act [KCSA], the presence of nominal and associate members is lawful and does not break the mutuality principle.

Consequences of Non-Compliance to TDS (Section 201)

July 5, 2025 8271 Views 0 comment Print

Understand the penalties, interest, and disallowance of expenditure under Section 201 for failure to comply with TDS provisions in India.

Sales Incentives to Retailers by Agent Not “Commission” U/S 194H: ITAT Hyderabad

June 19, 2025 633 Views 0 comment Print

The appellant-company has deducted TDS as per sec.194H of the Act on commission payment to Agent, however, not deducted any TDS on sales promotion and cash incentives paid to the retailers.

ITAT remands ₹2.31 crore addition for enquiry on cash deposits & Section 40(a) disallowance

June 14, 2025 327 Views 0 comment Print

Chennai ITAT remands Rs. 2.31 crore addition for cash deposits and S. 40(a) disallowance, directing AO to conduct fresh enquiry.

Section 14A Disallowance Invalid Without Exempt Income: ITAT Ahmedabad

June 13, 2025 438 Views 0 comment Print

ITAT Ahmedabad held that disallowance under section 14A of the Income Tax Act is called off in absence of any exempt income earned/ claimed. Thus, appeal of the assessee allowed and disallowance u/s. 14A set aside.

Adhoc disallowance of expense without contrary material not justifiable: ITAT Delhi

June 4, 2025 897 Views 0 comment Print

ITAT Delhi held that disallowance of expenditure on adhoc basis without contrary material and without rejection of books of accounts not justifiable. Accordingly, disallowance made in the impugned order deleted.

Reopening of assessment quashed as based on change of opinion: Bombay HC

May 31, 2025 1557 Views 0 comment Print

Bombay High Court held that since issue already examined during the course of assessment proceedings, re-opening of assessment on same issue amounts to change of opinion. Thus, re-opening based on change of opinion is not sustainable.

Disallowance u/s. 40(a)(ia) set aside as TDS not deductible on supply of foods packets: ITAT Jaipur

May 30, 2025 1449 Views 0 comment Print

ITAT Jaipur held that expenditure towards supply of food packets for employees which was subjected to GST shall not be considered as contract and hence provisions of section 194C shall not apply.

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