TDS applicability of section 194Q on payment for coal

As TDS provision of 194Q was applicable from 1.7.21. Coal is subject to TCS, however by submitting Form 27C, TCS was exempted. As TCS provision was applicable, TDS under 194 Q was not deducted. However, CBDT vide circular dt 25.11.21 clarified that when TCS is exempted vide Form 27C, TDS under 194Q will be applicable. Now, provision of 194Q was applicable since July 2021 but CBDT clarification came on 25 November 2021. whether non deduction of TDS from July 2021 to November 2021 will amount to be non compliance and interest will be charged ?