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Dcit, Cir-1(1), Kolkata, Kolkata vs M/S Landis + Gyr Ltd., Kolkata on 13 September, 2017

5. We have heard rival pleadings against and in support of the impugned disallowance. The assessee's case that its packed tea damages claim in question has ITA No.803/Kol/2018 Assessment Year 2011-12 Duncans Tea. Ltd. Vs ACIT, Cir-4(1) Kol. Page 5 been worked out to the tune of 0.01% of the total turnover only which is allowable as normal business expenditure. The Revenue on the other hand quotes lower authorities' findings that the impugned disallowance has been rightly made on account of assessee's failure in filing exact corresponding details. After giving our thoughtful consideration to rival pleadings, we observe that neither parties submission deserve to be accepted in entirety. The fact remains that assessee has not placed on record all the necessary details in either of the lower proceedings and the Revenue also fails to dispute that such a loss of packed tea cannot be altogether ruled out in regular business activity. We therefore conclude that a lump sum disallowance of ₹20,000/- only would meet the ends of justice with a rider that same shall not be treated as a precedent in any other assessment year. The assessee's latter substantive grievance is partly accepted.
Income Tax Appellate Tribunal - Kolkata Cites 55 - Cited by 28 - Full Document

Deputy Commissioner Of Income-Tax vs Continental Engineering Industries ... on 26 April, 1994

Besides, the Hon'ble Delhi High Court in the case of CIT Vs. Industrial Engg. Projects P. Ltd. (202 ITR 1014), held that it is a settled proposition of law that when there is no element of income and the payment is only as a reimbursement of expenses incurred by the payee, then no disallowance can be made u/s. 40(a)(ia) of the Act.
Income Tax Appellate Tribunal - Ahmedabad Cites 17 - Cited by 43 - Full Document

Satyendra Jhunjhunwalla, Howrah vs Ito, Ward - 46(2), Kolkata on 11 September, 2019

Therefore, the assessee was not obliged to deduct tax at source. We note that it is not a direct payment for freight to the transporter. Therefore, we are of the view that there is no TDS obligation on the assessee on the alleged amount of Rs.18,16,096/-. For that we rely on the judgment of the Co- ordinate Bench of ITA T Kolkata in the case of Satyendra Jhunjhunwalla Vs. ITO, W-46(4), Kolkata, ITA No.1988/Kol/2009, for the A.Y 2005-06, wherein it was held as follows:-
Income Tax Appellate Tribunal - Kolkata Cites 0 - Cited by 2 - Full Document
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