Dismissing the appeal of the reveniue the High Court held taht Section 194C(6) & (7) are independent of each other and cannot read together to attract disallowance under Section 40(a)(ia) read with Section 194C of the Act. Referred ACIT v. Arihant Trading Co. (2019 ) 176 ITD 397 (Jaipur(Trib). (AY. 2012-2013)
CIT v. Shri Parameshwari Spinning Mills P. Ltd. (2020) 317 CTR 898 (Pat) (HC)
S. 40(a)(ia): Amounts not deductible – Deduction at source – Payment to contarctor – Failure to furnish form No 15J – PAN no of was collected at the time of payment – No dialloawance can be made [ S. 194C (7), R, 31A ] S. 40(a)(ia): Amounts not deductible – Deduction at source – Payment to contarctor – Failure to furnish form No 15J – PAN no of was collected at the time of payment – No dialloawance can be made [ S. 194C (7), R, 31A ]