Held that the assessee had categorically stated before the Joint Commissioner that in the absence of receipt of actual invoices by the last day of the respective financial years, the provision for expenses was based on estimates. As a result, the assessee did not withhold taxes on the year-end provisions for expenses under section 40(a)(ia). As the assessee had neither claimed nor availed of any benefits of the provision made for expenses and had paid due taxes in full, there was neither any tax evasion nor loss of revenue to the Government. In the absence of any distinguishable features contrary to the view taken by the Commissioner (Appeals), the order of the Commissioner (Appeals) was to be upheld. (AY.2013-14)