Profarm Seed India P. Ltd. v. ITO (2023)101 ITR 120/ 198 ITD 113 (Hyd) (Trib)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Business expenditure-Disallowance-Remuneration to directors-Prior to 01.04.2015-Deduction allowable-Audit fees-addition justified.

Held, that That prior to April 1, 2015 the amount payable towards the salaries was not covered by the provisions of section 40(a)(ia) of the Act. Therefore, the addition on account of non-deduction of tax at source on the remuneration paid to the directors could not be sustained. Further, the addition on account of audit fee was justified by the provisions of section 40(a)(ia) of the Act and, therefore, did not warrant any interference.(AY. 2014-15)