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TMI Blog2024 (8) TMI 553X X X X Extracts X X X X X X X X Extracts X X X X ..... rms of sec. 201 - HELD THAT:- As noticed that the assessee has not remitted the above said amount to any other person. It has transferred the above said amount from its bank account maintained in India to its own bank account located in United Kingdom i.e., it is a case of transfer of funds by the assessee to itself. The provisions of section 195 shall come into operation only if a person is makin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has filed this appeal challenging the order dated 18-03-2024 passed by the Ld.Addl/JCIT(A)-4, Kolkata (in short Ld.CIT(A) ) and it relates to AY. 2016-17. 2. The only issue urged in this appeal is related to the demand raised by the AO u/s. 201 of the Income Tax Act, 1961 ( the Act ), treating the assessee as assessee in default for not deducting tax at source u/s. 195 of the Act in respect of cer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 195 of the Act from the above said remittances. Since the assessee did not deduct tax at source, he treated the assessee as an assessee in default and raised a tax demand of Rs. 65.50 crores, u/s. 201(1) of the Act and interest demand of Rs. 39.95 crores u/s. 201(1A) of the Act, both aggregating to Rs. 159.65 crores. 5. There is some confusion about the assessment year. We noticed that the remitt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emitted the above said amount to any other person. It has transferred the above said amount from its bank account maintained in India to its own bank account located in United Kingdom i.e., it is a case of transfer of funds by the assessee to itself. The provisions of section 195 of the Act shall come into operation only if a person is making payment to any other person of any sum chargeable under ..... X X X X Extracts X X X X X X X X Extracts X X X X
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