Explanation 3 to section 11(1) read with section 40(a)(ia)

DHANYA.G (Practicing Chartered Accountant)   (43 Points)

28 November 2024  

A Trust has not deducted TDS for certain expenses. However these expenses are not treated as application. However Assessing Authority has proposed addition of 30% of such expenses based on Explanation 3 to section 11(1) read with section 40(a)(ia) treating 30% of such expenses as addition. Is this correct?Since the Trust has not considered such expense as application whether the proposed addition is tenable in law?