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TMI Blog2022 (12) TMI 649X X X X Extracts X X X X X X X X Extracts X X X X ..... ns of Section 40(a) (ia) - Thus, we do not find any error in the action of the CIT(A) in upholding the disallowance made by the A.O. Accordingly, the grounds of appeal of the assessee are dismissed. - I.T.A. No. 6294/DEL/2018 - - - Dated:- 14-12-2022 - DR. B. R. R. KUMAR , ACCOUNTANT MEMBER AND SH. YOGESH KUMAR U. S. , JUDICIAL MEMBER Appellant by : None ; Respondent by : Shri Amit Shukla , Sr. D. R. ; ORDER PER YOGESH KUMAR U. S. , JM This appeal is filed by the assessee for assessment year 2014-15 against the order of the ld. Commissioner of Income Tax (Appeals)-28, New Delhi, dated 11.07.2018. 2. The assessee has raised the following substantive grounds of appeal:- 1. That the order of the learned ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... None appeared for the assessee, the notice sent to the registered address returned with an endorsement LEFT . Therefore, we are constrained to decide the Appeal on hearing the Ld. DR and verifying the material on record. 7. We have heard the Ld. DR perused the material on record and gave our thoughtful consideration. 8. The Ld.CIT(A) while confirming the disallowance of Rs. 1,06,17,768/- made by the A.O. has held as under:- 7.2 The Fourth Ground pertains to the disallowance made on account of lower deduction of tax at source than permitted by the AO. It was observed by AO that the expenses on account of payments of Rs. 1,82,45,461/- to Media Pro Enterprises (P) Ltd and Rs. 46,34,850/- to India Cast Media Distribution (P) Ltd wer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion as per said section, it transpires that the appellant has not been able to fulfill any of three conditions i.e. by showing or furnishing evidence of the fact that the resident or assessee (in whose case TDS was to be made) has furnished his return of income u/s 139(1) of the Act, the said resident has taken into account the relevant amount on which TDS was to be made for computing income in his return of income and thirdly, the appellant has failed to give any details or evidence that the said person has paid tax due on the income declared by him in such return of income. During the appellant proceedings also, appellant failed to give any reason for not fulfilling the aforesaid conditions as envisaged by Section 201(1) of the I.T, Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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