Tribunal held that the considering the totality of the facts of the case and in the interest of justice the issue was restored to the Assessing Officer with a direction to grant one opportunity to the assessee to substantiate that the recipient had filed its return declaring the interest amount in the income and paid due taxes thereon and decide the issue keeping in mind the provisions of section 201(1A) . ( AY.2010-11)
Barnala Steel Industries Ltd. v JCIT (2020) 78 ITR 29(SN) (Delhi) (Trib)
S. 40(a)(ia): Amounts not deductible – Deduction at source – Failure to deduct tax on interest paid on loan- Recipient had declared the interest in the return- The assessee is directed to substantiate that recipient has shown the interest in his return. [ S.194A, 201(IA) ]