Assessee made payments to transporters towards freight charges without deducting TDS on same on ground that transporters had furnished their respective PANs to assessee at time of payment of freights. Assessing Officer held that the assessee could not furnish PANs of transporter to prescribed Income tax authority as per requirement of section 194C(7) accordingly disallowed the payment applying the provision of S. 40(a)(ia) of the Act. Tribunal held that   provisions of S. 40(a)(ia) which are deeming fiction relating to non-deduction of TDS have to be read in limited context of non-deduction of TDS and same cannot be extended to ensure that even where assessee complies with his statutory obligation not to deduct TDS on receipt of PAN, merely because subsequent obligation in terms of filing of prescribed forms has not been complied with. Accordingly the deletion of addition by CIT(A) is affirmed. (AY. 2015-16)