sec. (2) of sec. 194C , Explanation (ii) to sec. 194I , Explanation (c) to
Sec. 194J , Explanation (iv) to Sec. 194H and Explanation 1 to sec ... provisions of this section shall
apply accordingly. Similar provision such as Sec. 194(2) exists in Sec. 194H
Explanation (ii) of the Act which applies
sec. (2) of sec. 194C , Explanation (ii) to sec.
194I , Explanation (c) to Sec. 194J , Explanation (iv) to Sec. 194H
ITA No.1195/Bang/2014 ... sec. 194C
(b) Professional fees covered by sec. 194J
(c) Rent expenses covered by sec. 194I
(d) Commission expenses covered by sec.194H
(e) Payments
sec. (2) of sec. 194C , Explanation (ii) to sec. 194I ,
Explanation (c) to Sec. 194J , Explanation (iv) to Sec. 194H and
Explanation 1 to sec ... sec. 194C
(b) Professional fees covered by sec. 194J
(c) Rent expenses covered by sec. 194I
(d) Commission expenses covered by sec.194H
(e) Payments
provisions of sec. 40(a)(ia) and sec. 201 operate on
different objectives. We have already noticed that the provisions of sec ... used in all the sections was that tax had to be deducted out of the
sum payable to residents. Section 194H talks of payment
amount u/s disallowed under Section
40(a)(ia) ...................the
same cannot be subject to the provisions of TDS under Section ... Mumbai, where the disallowance u/s 40(a)(ia) for non
deduction of TDS-
- u/s 194H Rs. 11,64,93,420
- u/s 194JRs
leads, that when the obligation of Section 194C of
the Act is not complied with, the consequences under Section
40 [a][ia] will operate ... aspects are
considered with respect to Section 40(a)(ia) of the Act read
with Sections 194C , 194H , 1941, 194J -- relevant
Sections under which
leads, that when the obligation of Section 194C of
the Act is not complied with, the consequences under Section
40 [a][ia] will operate ... aspects are
considered with respect to Section 40(a)(ia) of the Act read
with Sections 194C , 194H , 1941, 194J -- relevant
Sections under which
M/S Dell International Services India ... vs Additional Commissioner Of Income Tax ... on 7 August
raised ground against the
penalty u/s 271C of
Rs.24,16,490/-.
3. As per the provisions of section 271C if any
person fails ... royalty payments. TDS required to be made and
deposited u/s 194C , 195 , 194H , 1941 and 194J was
deposited later with interest hence the appellant