9911796707
TMI Blog2024 (10) TMI 587X X X X Extracts X X X X X X X X Extracts X X X X ..... fee. As the assessee had paid a salary to its accountant and the total sum paid as a salary is below the taxable limit, there was no liability to deduct the tax at source u/s 192 of the Act. Therefore, since the alleged sum of ₹ 1,44,000/- is a salary expenditure and not a payment towards Professional or Technical Services, no disallowance was called for u/s 40(a)(ia) for non-deduction of tax at source u/s 194J of the Act. We therefore, set aside the finding of CIT (A) and delete the impugned disallowance and allow, the effective ground of appeal raised by the assessee is allowed. - Shri Rajpal Yadav, Vice President And Shri Dr. Manish Borad, Accountant Member For the Assessee : Shri AK Rastogi, Sr. Adv. For the Revenue : Shri Ashw ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... act remains that the appellant has uploaded the ground-wise written submission way back on 19/05/2023 and much before the date of compliance on 22/05/2023 in response to notice dated 15/05/2023. 3. For that the Ld. CIT(A) has erred in holding that Ground No.1, 3, 4, 5, 7, 9, 12, 14 15 are general in nature and does not require any separate adjudication especially considering the fact that the appellant has not furnished any submission in support of the grounds and therefore, thse grounds remained unsubstantiated. 4. For that the Ld. CIT(A) has erred in holding that the AO has given proper opportunity of being heard and that the appellant has not availed the opportunity so granted and there is no violation of principles of natural justice on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ally at the time of hearing of the appeal. 13. For that the whole order is bad in fact and law of the case and is fit to be annulled. 14. For that the other grounds, if any, shall be urged at the time of hearing of the appeal. 4. Though the assessee has raised 14 grounds of appeal but the sole grievance is against the disallowance u/s 40(a)(ia) of the Act at ₹ 1,44,000/- for the alleged non-deduction of tax at source u/s 194J of the Act on the accountancy charges debited in the profit and loss account at ₹ 1,44,000/-. The learned Authorized Representative submitted that the assessee has paid monthly salary to his accountant at the rate of 12,000/- per month and the same is not liable for deduction of tax at source. 5. On the oth ..... X X X X Extracts X X X X X X X X Extracts X X X X
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