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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 1257 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 9021 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 12669 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 11850 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 2589 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 151323 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 1137 Views 0 comment Print


Latest Judiciary


Section 80-IA Deduction Upheld as Market Value Must Be Based on Electricity Board Consumer Rates

Income Tax : The Delhi High Court held that the issues raised by the Revenue were either covered by binding precedents or based on factual find...

July 1, 2026 99 Views 0 comment Print

ITAT Mumbai Restricts Section 14A Disallowance as It Cannot Exceed Exempt Income

Income Tax : The Tribunal restricted the Section 14A disallowance to exempt income and deleted additions relating to bad debts, tea and coffee ...

June 28, 2026 225 Views 0 comment Print

ITAT Deletes Section 40(a)(ia) Disallowance as Payments Stayed Below TDS Threshold

Income Tax : The ITAT Chandigarh held that no TDS was deductible where professional fees paid to each payee were below the statutory threshold....

June 28, 2026 144 Views 0 comment Print

Bangalore ITAT Allows Mine Development Expenditure as Revenue Expense; Deletes Double Addition

Income Tax : Bangalore ITAT held that mine development expenditure incurred by a mining contractor was allowable as a revenue deduction under S...

June 24, 2026 81 Views 0 comment Print

ITAT Allows Gratuity Deduction as Contribution Was Made to Approved Gratuity Fund

Income Tax : The ITAT Delhi held that an adjustment against excess contributions already made to an approved gratuity fund could not be disallo...

June 23, 2026 309 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 5610 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 15305 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 21638 Views 0 comment Print


ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

June 17, 2026 246 Views 0 comment Print

The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of international transactions. It directed inclusion and exclusion of specific comparables and partly allowed the assessee’s appeal.

Bombay HC Upholds 0.5% Corporate Guarantee Fee; No Section 40(a)(ia) Disallowance for Short TDS Deduction 

June 17, 2026 219 Views 0 comment Print

The Bombay High Court held that a corporate guarantee cannot be equated with a bank guarantee and upheld a 0.5% guarantee commission rate. The Court rejected the Revenue’s challenge to the 3% rate adopted by the Transfer Pricing Officer.

No Escape from TDS on Identified Year-End Provisions; ITAT Grants Relief Where Tax Paid Before Return Due Date

June 15, 2026 213 Views 0 comment Print

The ITAT found that provisions for identified legal and professional expenses represented crystallized liabilities requiring TDS deduction. The key takeaway is that only genuine contingent liabilities may escape such obligations.

No Tax on Inter-Circle Reconciliation Differences: ITAT Deletes ₹1,527 Crore Addition

June 15, 2026 300 Views 0 comment Print

 Inter/Intra Circle Remittance Balance represented only internal transfer and reconciliation entries relating to assets and stock in transit between different Circles of the Assessee company. Since no expenditure or deduction had been claimed and the balances did not represent any real income or loss, the addition of Rs.1527.40 crores made by the AO and confirmed by the CIT(A) was deleted.

Compensation for Cancelled Land Sale Allowed as It Was for Commercial Expediency: ITAT Chennai

June 8, 2026 195 Views 0 comment Print

The ITAT held that compensation paid to terminate a land sale agreement was a business expenditure incurred for commercial reasons. The amount could not be treated as part of closing stock and was allowable under Section 37.

Section 194C TDS not applies on materials purchased for installation work: ITAT Kolkata

June 8, 2026 276 Views 0 comment Print

ITAT Kolkata held that TDS under Section 194C was not required on materials purchased for installation work. The disallowance under Section 40(a)(ia) was reduced substantially after excluding the material component.

ITAT Allows Advertisement Expenses as Sponsorship & Promotional Activities Were Business-Related

June 7, 2026 159 Views 0 comment Print

The Tribunal deleted the disallowance of advertisement and publicity expenses after finding that sponsorship of football teams, tournaments, and green movement initiatives was undertaken for business promotion. It held that such expenditure qualified as allowable business expenses.

APMC Cess Does Not Prove Unaccounted Turnover: ITAT Mumbai

June 6, 2026 150 Views 0 comment Print

ITAT found that the Assessing Officer incorrectly treated consignment transactions as the assessees turnover based solely on cess payments. The ruling emphasizes that commission agents should be taxed on commission income and not on consignors turnover.

Bangalore ITAT: Write-Off in Books Is Enough for Bad Debt Claim; Ad-Hoc Expense Disallowance Struck Down

June 4, 2026 345 Views 0 comment Print

The Bangalore ITAT held that an assessee need not prove that a debt has actually become irrecoverable to claim a bad debt deduction. The Tribunal ruled that a proper write-off in the books of account is enough to qualify for the deduction.

ITAT Mumbai in AY 2010-11: Extensive Ruling on Banking Taxation Issues

May 31, 2026 1134 Views 0 comment Print

State Bank of India Vs ACIT (ITAT Mumbai) The Mumbai Bench of the Income Tax Appellate Tribunal decided cross-appeals filed by a public sector bank and the Revenue for Assessment Year 2010-11. The case involved a large number of recurring banking-taxation issues including pension provisions, depreciation on securities, bad debts, section 14A disallowance, taxation of […]

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