1) Can the AO issue notice u/s 148 for making disallowance u/s 40(a)(ia)?
2) First authority remands matter to AO to verify date of submission of Form 15G/H for payment of interest without deducting TDS so as to allow such payment u/s 40(a)(ia). Assessee awaits order giving effect but finds it against him. Hence, appeal is filed before the Honourable Tribunal against order giving effect to CIT-A within 30 days of date of receipt OGE. Is this a wrong remedy? Should the appeal be filed only against CIT- Appeal order within 30 days?