if a company has given loan to someone say on 01.04.2013 and no interest has been charged and no tax has been deducted from that loan amount given but later on some services(Contractor Services)say on 1.1.14 has been taken from that person and loan has been set off against that interest payment and TDS has been adjusted. will the liability of TDS will arise on the date of loan or on the date of receiving services?