2011 (12) TMI 584

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..... ement of the exact amount which has been paid to the airlines towards freight charges. There is no finding that these agents deliberately separated/bifurcated the bills and service charges were independently paid or were included in the said bills. With regard to the second addition of 8,84,881/-, the concurrent findings recorded by the CIT(Appeals) and ITAT are that the said payments were less th .....

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..... 8,84,881/- under Section 40(a)(ia) of the Income Tax Act, 1961 (Act for short) on account of failure of the assessee to deduct tax at source (TDS) under Section 194C of the Act. The CIT (Appeals) and Income Tax Appellate Tribunal have deleted the said addition. With regard to addition of ₹ 30,66,703/- the two appellate authorities have concurrently held that this payment was not on account .....

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..... d/bifurcated the bills and service charges were independently paid or were included in the said bills. With regard to the second addition of ₹ 8,84,881/-, the concurrent findings recorded by the CIT(Appeals) and ITAT are that the said payments were less than ₹ 50,000/- to a single party and, therefore, TDS under Section 194C was not required to be deducted. Learned counsel for the app .....

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