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Rajendra Singh Yadav vs I.T.O.Ward-4,Bhilwara on 14 May, 2013

10. Following the above decision, we set aside the orders of the authorities below and direct the assessing officer to follow the order of ITAT, Jaipur Bench in the case of Shri Rajendra Yadav vs., ITO (supra), and in case of disallowance under section 40(a)(ia) of the Income Tax Act, 1961, the same should be restricted to 30% only as against 100% because the amended provision is curative in nature 35 ITA.No.6724/Del./2018 M/s. R.H. International Ltd., New Delhi.
Rajasthan High Court - Jodhpur Cites 0 - Cited by 19 - A Bhansali - Full Document

Anz Grindlays Bank vs Dy. Commissioner Of Income-Tax, ... on 29 August, 2003

and have made to remove the undue hardships to assessee and accordingly should be applied retrospectively. 10.1. Learned Counsel for the Assessee further submitted that deductees have filed their ITR under section 139(1) and have shown the same amount as income, which have been offered to tax and have also paid the taxes thereon. All the documentary evidences are available on record. Learned Counsel for the Assessee relied upon Judgment of the Hon'ble Calcutta High Court in the case of Grindlays Bank vs., CIT (supra) and submitted that double tax should not be recovered from the assessee. The Learned CIT(A), however, noted that the provision contained in second proviso to Section 40(a)(ia) is not applicable to the case of the assessee because assessee had fully deducted the TDS, but, did not deposit the same into the Government account. However, assessee explained reasonable cause for failure to comply with such provision, on which, Learned CIT(A) admitted the additional evidences. In case the deductees have also paid the taxes on such receipts and offered the amount for taxation, it would certainly amount 36 ITA.No.6724/Del./2018 M/s. R.H. International Ltd., New Delhi.
Income Tax Appellate Tribunal - Delhi Cites 28 - Cited by 26 - Full Document
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