2024 (2) TMI 345 - SCH - Income Tax

TDS u/s 194C - Disallowance u/s 40(a)(ia) - payment of transportation of goods - sub-contracting - scope of the term 'Work' - ITAT deleted addition - whether the provisions of Section 194C of the Act can be invoked only if any single payment exceeds ₹ 50,000/- or can be invoked if the aggregate of payment in an assessment year exceeds ₹ 50,000/-. As decided by HC 2015 (10) TMI 825 - KARNATAKA HIGH COURT Tribunal has diverted itself from addressing the core issue, that is whether the assessee has paid any sums, the aggregate of which exceeds ₹ 50,000/- in the assessment year to any single entity. Tribunal has not addressed itself to any of the findings of fact rendered by the Assessing Authority - It does not render any reasoning to unsettle the finding of the original authority, that even the agreement can also be an oral and that the transactions with the lorry owners/transporters is within the purview of the provisions of the Act as it amounts to carriage of goods other than the railways and decided issue in favour of the revenue. HEKD THAT - Leave granted.

Summary

The Supreme Court of India granted leave in the case. Justices Pamidighantam Sri Narasimha and Aravind Kumar presided over the matter. Key representatives included Mr. S.Annamalai, Mr. N Venkatraman, and others.