Ramaniyam Real Estates Private Limited vs. ACIT, Circle -1, LTU, Chennai
Parties Involved
Facts Summary
The assessee, Ramaniyam Real Estates Private Limited, filed its return of income on 20.09.2018 declaring a total income of Rs.19,97,07,100/-. The case was selected for scrutiny through CASS. Various statutory notices were issued to the assessee, to which the assessee responded. Upon examination, the Assessing Officer (AO) completed the assessment on 30.09.2021 under sections 143(3) and 144B of the Income Tax Act, 1961, determining the total income of the assessee at Rs.20,11,43,424/-. The AO disallowed 30% of the total amount of Rs.47,87,748/-, amounting to Rs.14,36,324, under section 40(a)(ia) of the Act for alleged non-deduction of tax at source on rent, professional fees, wages, and AMC charges. The assessee appealed against this order before the Learned Commissioner of Income Tax (Appeals), who confirmed the disallowance. Aggrieved, the assessee filed an appeal before the Income Tax Appellate Tribunal.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the order of the NFAC, Delhi dated 13.08.2025 is contrary to law, fact, and circumstances of the case.
- 2. Whether the NFAC, Delhi erred in sustaining the disallowances under Section 40(a)(ia) of the Act for want of TDS.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
2 precedents cited in this judgement.
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