Assessee was engaged in the business of real estate. Assessee claimed that in POCM, revenue was recognised when a substantial amount of sale was realized, and corresponding construction was yet to be completed, and physical possession was not given to the buyer. Thus, in order to provide parity between revenue and expenses, a provision was made for expenses that were going to be incurred in future. Since it was a provision made for future expenditure, there was no question of making TDS out of same. Assessing Officer made a disallowance of a certain amount of expenses under section 40(a)(ia) on account of non-deduction of tax at source. CIT(A) deleted disallowance on the basis of submissions of assessee that this related to the provision towards material. However, no opportunity was given to Assessing Officer for making verification of this fact. On appeal by revenue, the Tribunal directed the Assessing Officer to verify whether claim of assessee that amount related to provision for material and further verify whether due TDS was deducted and deposited on service portion before filing of return of income and decide the issue in accordance with law and also keeping in mind the method of revenue recognition followed by assessee. (AY. 2019-20)