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TMI Blog2017 (6) TMI 1245X X X X Extracts X X X X X X X X Extracts X X X X ..... 40 (a) (ia) of the Income Tax Act, 1961 cannot be made. This issue is covered in favour of the assessee by judgment of this Court in the case of J.K.Construction Co. [2013 (2) TMI 54 - GUJARAT HIGH COURT]. This question is, therefore, not required to be considered. Enhancement under Section 40 (a) (ia) - charges paid to the truck owners for transportation of the goods - Held that:- AO as well ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Tribunal dated 6.10.2016. Following questions are raised for our consideration. [A] Whether the Appellate Tribunal is right in law and on facts in deleting the disallowance of ₹ 1,11,73,780/- made under Section 40 (a) (ia) of the Income Tax Act, 1961? [B] Whether the Appellate Tribunal is right in law and on facts in deleting the enhancement under Section 40 (a) (ia) of the Act m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... portation of the goods. The Assessing Officer as well as CIT (Appeals) proceeded on the basis of such transportation being in the nature of a contract, required deduction of tax at source. The Tribunal, however, held that there is nothing on record to suggest that there was any relationship of contractor and contractee between the assessee and the truck owners. The assessee had merely hired the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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