Transport Payments Exempt from TDS Under Section 194C(6) When Sub-Contractors Own Fewer Than 10 Goods Carriages

The ITAT allowed the appellant's appeal against disallowance under section 40(a)(ia) for non-deduction of TDS on payments to transport sub-contractors. The Tribunal held that the appellant had properly complied with section 194C(6) by collecting declarations from 12 sub-contractors confirming they owned fewer than 10 goods carriages, which exempted these payments from TDS requirements. Despite the AO's and CIT(A)'s contentions, the appellant had filed quarterly E-TDS returns within prescribed deadlines, issued Form 16A to contractors, and uploaded relevant contractor details as required. The ITAT concluded the authorities erred in making the disallowance when statutory compliance had been demonstrated. .....

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