Held, that admittedly, the assessee had reversed the provision on the first day of the next previous year. As the payer and the payee were identified, the nature of services was also ascertained and the amount of liability determined, there was no reason why the tax should not have been deducted thereon. Only in those circumstances provisions of section 40(a)(ia) of the Act would apply. However, if the assessee paid such tax on or before the due date specified under section 139(1) of the Act, no disallowance could be made. Even if it was accepted that tax should have been deducted, the assessee has subsequently deposited the impugned amount of tax deducted on or before the due date under section 139(1) of the Act for the year in which provision was made. As the assessee had complied with that condition, for different reasons, the addition could not be sustained. (AY.2014-15