14 September 2013
Section 40(a)(ia) is applicable only in respect of TDS default if amount is payable. If amount is actually paid and tax is not deducted under the specified sections, section 40 (a)(ia) in not applicable.
14 September 2013
Please refer the Special bench tribunal decision in
Merilyn Shipping & Transport Ltd reported in 136 ITD 23
where in it was held that section 40(a)(ia) applied only to amounts that were “payable” as at the end of the year and not to amounts that had already been “paid” during the year.