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TMI Blog2018 (8) TMI 1744X X X X Extracts X X X X X X X X Extracts X X X X ..... on thereon which does not require any interference - decided against revenue TDS u/s 194C - disallowance u/s 40(a)(ia) - assessee had contracted work with sub-contractors with non deduction of tds on payments - CIT-A had deleted the disallowance on verification of facts available on record that the assessee had indeed deducted tax at source on sub-contract payments made to aforesaid two parties and remitted the TDS to the account of the Central Government, which is supported by TDS certificates which were available in the assessment records itself. Hence we find no infirmity in the order of the ld CIT-A. - decided against revenue X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,12,000/- B J Construction ₹ 14,49,700/- Total ₹ 31,58,367/- The ld AO sought to verify the veracity of these loan creditors by issuing notice u/s 133(6) of the Act calling for various details. No reply was received from these loan creditors. Accordingly, the ld AO proceeded to add the same as unexplained cash credit u/s 68 of the Act and added the same to the total income of the assessee. 3.2. The assessee submitted that he had borrowed loans from his near relatives and friends in the earlier assessment years and the unsecured loans were duly reflected in his balance sheet and the said unsecured loans of ₹ 31,58,367/- were brought forward from earlier years and not the loans borrowed during the year. The ld CITA on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is that the assessee had contracted work with subcontractors M.D.Construction and M/s Pratibha Electronic Works amounting to ₹ 89,61,050/- and ₹ 11,11,111/- respectively totaling to ₹ 1,00,72,161/- and made payment thereon without deduction of tax at source u/s 194C of the Act. Accordingly, the ld AO proceeded to make disallowance u/s 40(a)(ia) of the Act to the tune of ₹ 1,00,72,161/-. The assessee submitted that the sub-contract payments made to M/s M.D.Construction and M/s Pratibha Electronic Works amounting to ₹ 89,61,050/- and ₹ 11,11,111/- were duly subjected to deduction of tax at source in terms of section 194C of the Act in support of which, copy of TDS certificate in Form No. 16A issued to thos ..... X X X X Extracts X X X X X X X X Extracts X X X X
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