said to be „closely linked‟,
if they emanate from a common source, being an order or contract or an
agreement or an arrangement ... characteristic and terms of
such transactions substantially flow from the said common source. The
following extract from the said Guidance Notes is worthy of notice
5114/Mum/2012 vide common orders
dated 09-07-2014 has concluded the issue of deductibility of tax at source on
PSF by holding ... deduction of tax at source on cargo
handling charges incurred by the assessee wherein the assessee deducted tax
at source u/s 194C while Revenue
even otherwise, represents a common
sense, purposive view of the matter; TDS being only manner of
recovery of tax, so that it would, subject ... extent
of the amount of TDS proportionate to the same. That is, if the TDS rate is
10 % (say), at Rs. 0214 lakhs. In fact
Cantt Board, Ajmer vs Income Tax Officer (Tds), Ajmer, Ajmer on 18 September, 2017
vk;dj vihyh ... convenience and
brevity, common order is being passed.
2 ITA 660 to 664/JP/2017_
Cantt Board Vs ITO (TDS)
3. In all these appeals
appeals filed by the assessee since involve common
issue therefore, all these appeals are decided by this common order, as
agreed by both the parties ... common ground of appeal:
"1. The Order of the Commissioner of Income
Tax(Appeals)-lll, Kochi, in I.T.A.
No.27/TDS
exempted income
from different sources. Once the business is composite and
the expenditure incurred by the appellant
includes common indirect expenses as is evident from
Shirur, Dist. Pune - 412 208
PAN : AABCA4586B .... अपीलाथ /Appellant
Vs.
Addl.CIT (TDS), Pune .... थ / Respondent
Assessee by : None
Revenue by : Dr. Vivek Aggarwal ... appeals are filed
against the separate orders of CIT(A)-10, Pune commonly dated
18-12-2015 in connection with the penalty u/s.271C
Motisons Global Pvt. Ltd., Jaipur vs Acit, Jaipur on 2 November, 2017
vk;dj vihyh
bank statement. It is also pertinent to mentioned that
the source of payment as per the bank statement is also deposits of
cheque by clearing ... Jain and the
directors of the cash creditor company is not the common director in
the said company. The AO alleged that the cash creditor
borrowings made from the co-operative financial institutions. The
assessee has common kitty of funds consisting of reserves, the share
capital deposits and borrowings ... long term loans out of the
borrowings of the society and other sources required to be ascertained
and the correct amount of statutory reserve should
