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There are two effective grounds raised in this appeal by the assessee; Firstly, whether the assessee was rightly treated as assessee in default, for not-deducting TDS on rent paid to Krishi Upaj Mandi Samiti, Dhamnod & Khandwa and secondly, whether there was Short Deduction of TDS on rent paid to co-owners (M/s Sadhna Enterprises) and the applicability of the provisions of section 194I of the Act.

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Section 194-I of the Income-tax Act, 1961—Deduction of tax at source—Assessee should not be treated as assessee in default for short deduction of tax on rent payment since the assessee has rightly deducted, collected and paid the tax on share of the rent paid to each of the co-owners and revenue authorities failed to bring any contrary material to prove that the total rent was paid , since the rent have been paid to each of the co-owners, tax deductible at source as per the provisions of section 194I has been complied by the assessee. - M.P. WAREHOUSING & LOGISTICS CORPORATION V/s ACIT - [2020] 183 ITD 485 (ITAT-INDORE)

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