2020 (9) TMI 976

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..... nt to the assessment year under consideration and not amounts which are payable at any time during the relevant previous year? - HELD THAT:- Tax effect is said to be less than the monetary limit imposed and therefore, the Appeal filed by the Revenue is dismissed, as withdrawn, keeping open the substantial questions of law for determination in appropriate cases.
THE HON'BLE DR.JUSTICE VINEET .....

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..... the Act, the term 'payable' would include amounts which are paid during the previous year? (ii) Whether on the facts and circumstances of the case, the ITAT was right in law in holding that the provision of section u/s.40(a)(ia) of the Act cover only the amounts which are payable as on 31st March of a previous year relevant to the assessment year under consideration and not amounts which are pa .....

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..... der dated 02.08.2013 of Mumbai ITAT in the case of ACIT, Cir.4(2) Mumbai vs. Rishti Stock & Shares (P) Ltd - ITA No.112/Mum/2012 and further whether order of ITAT had turned perverse in view of ratio of decision in the case of Sudarshan Silk Sarees vs. CIT 306 ITR 205 (SC)?" 2. When the matter is taken up for hearing, learned Senior Standing Counsel brought to our notice the Circular instruction .....

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