Claim of TDS liability under different provision i.e u/s 194I as against u/s 194J - It is not possible...

Claim of TDS liability under different provision i.e u/s 194I as against u/s 194J - It is not possible to import the existence or the consideration of any point not raised and adjudicated before the authorities or the Tribunal, much against the principles of natural justice and that too at this juncture in the appeal proceedings under the fiscal statute. - HC .....

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