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The issue raised by Revenue with respect to the disallowance under Section 40(a)(ia) is already covered by a judgment of this Court in CIT v. Rajinder Kumar [2014] 220 Taxman 3/362 ITR 241 (Delhi) and also theCITv.Ansal Land Mark Township Pvt. Ltd.[2015] 234 Taxman 825/377 ITR 635 (Delhi). In these circumstances, we are of the opinion that no question of law arise.

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Section 40(a)(ia) of the Income-tax Act, 1961—Business disallowance— Tribunal was justified in upholding the decision of CIT(A) which held that Assessing Officer was wrong in adding back the amount on the ground that the TDS has not been deducted as the payee i.e. the Delhi Transport Corporation had reflected the amount as its tax liability in its returns - PR. CIT V/s SHIVAAI INDUSTRIES (P.) LTD. - [2018] 1 ITCD Online 361 (DEL)

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